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PUBLIC CONSULTATION 
ON MUNICIPAL 



MM 1 * «* 



SOLID WASTE MANAGEMENT - 
"TOWARDS A SUSTAINABLE 
WASTE MANAGEMENT SYSTEM" 
JULY TO OCTOBER, 1990 



i 






JUNE 1991 





Environment 
Environnement 



ISBN 0-7729-8584-7 



PUBLIC CONSULTATION ON MUNICIPAL SOLID WASTE 
MANAGEMENT - "TOWARDS A SUSTAINABLE WASTE 
MANAGEMENT SYSTEM", JULY TO OCTOBER, 1990 



WASTE MANAGEMENT BRANCH 
ONTARIO MINISTRY OF THE ENVIRONMENT 



JUNE 1991 



o 

ncrcuu 



Cette publication technique 
n'est disponible qu'en anglais. 



Copyright: Queen's Printer for Ontario, 1991 
This publication may be reproduced for non-commercial purposes 

with appropriate attribution 



PIBS 1579 



Copyright Provisions and Restrictions on Copying: 

This Ontario Ministry of the Environment work is protected by Crown 
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for Ontario. It may be reproduced for non-commercial purposes if credit is 
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It may not be reproduced, in all or in part, part, for any commercial purpose 
except under a licence from the Queen's Printer for Ontario. 

For information on reproducing Government of Ontario works, please 
contact Service Ontario Publications at copyright @ontario,ca 



TABLE OF CONTENTS 



Page 



EXECUTIVE SUMMARY i 

1.0 INTRODUCTION 1 

2.0 PUBLIC CONSULTATION METHODOLOGY 1 

3.0 SUMMARY OF PUBLIC COMMENTS 3 

3.1 Public Comment Source - Stakeholder Groups .... 3 

3.1.1 Public Sector 4 

3.1.2 Private Sector 4 

3.2 Public Comment Type - Highlighted or General ... 4 

3.2.1 Highlighted Public Comments 5 

3.2.1.1 Municipal Solid Waste Management - 

General 5 

3.2.1.2 Waste Management Planning and Approvals 5 

3.2.1.3 3Rs of Waste Management 5 

3.2.1.4 Financial Sustainability 6 

3.2.1.5 Treatment /Disposal 6 

3.2.1.6 Other 6 

3.2.2 General Public Comments 6 

3.2.2.1 Municipal solid waste management - 

General 8 

3.2.2.2 Waste Management Planning and 

Approvals 10 

3.2.2.3 3Rs of Waste Management 13 

3.2.2.4 Financial Sustainability 18 

3.2.2.5 Treatment/Disposal 21 

3.2.3 Media Reporting 23 

4.0 CONCLUSIONS 23 

Appendix A A Report on Public Consultation undertaken 

for the Ministry of the Environment on its 
discussion paper: Towards a Sustainable 
Waste Management System , Perley and Hurley 
Ltd. 



Appendix B 
Appendix C 
Appendix D 



Discussion Paper Response Letter Log - 
Tally of Comments 

Newspaper Reporting of the Public 
Consultation Program 

July 9, 1990 News Release "Expanded 3Rs, 
Full-Cost Accounting, Tougher Standards Seen 
as Keys to Sustainable Waste Management" 



Appendix E 



Schedule of Public Consultation by Waste 
Management Branch Staff 



EXECUTIVE SUMMARY 

Public consultation on municipal solid waste management was 
undertaken during the period July to October, 1990. 
Concerned citizens, business, public interest groups and all 
levels of government were consulted to elicit views on how 
best to create a sustainable waste management system in 
Ontario. The goal of the public consultation program was to 
hear the public's ideas and concerns about the current waste 
management system in order that a consensus could be reached 
for improvements during the decade ahead. 

A discussion paper entitled "Towards a Sustainable Waste 
Management System" was prepared in support of the public 
consultation program and utilized as a framework for 
discussion. The discussion paper outlines Ontario's goal 
for municipal solid waste management, the underlying prin- 
ciples of a sustainable waste management system and the 
existing waste management programs supported by the Ontario 
Government. Discussions touched on how best to improve 
municipal solid waste management during the decade ahead and 
focused on important topics such as planning, financial 
sustainability, the 3Rs of waste management as well as 
treatment and disposal. 

Thirty presentations were made by Ministry staff to a wide 
variety of external groups who requested the opportunity to 
convey their ideas and concerns. Widely publicized public 
forums included events at Windsor, North Bay, Sudbury, 
Thunder Bay and Scarborough. Other audiences for Ministry 
presentations, in addition to concerned citizens, included 
representatives of key stakeholder sectors such as 
industrial/commercial waste generators, the waste management 
industry, federal and municipal officials and public inter- 
est groups . More than one hundred letters were received by 
the Ministry from a variety of sources as a direct conse- 
quence of the public consultation program. 

The purpose of this report is to summarize the comments and 
advice given to the Ministry arising from the public consul- 
tation program on municipal solid waste management. Several 
hundred public comments were received by the Ministry both 
in terms of today's concerns as well as ideas for the 
future. The tone and frequency of each specific public 
comment expressed by a wide variety of individuals was 
highly variable. In an effort to distil the public comments 
into helpful guidance to the Ministry on the future 
priorities for municipal solid waste management, sources of 
each comment are identified where possible, along with an 
indication of the frequency where similar comments were 



11 



received. Public comment sources were divided into the fol- 
lowing six stakeholder groups: concerned citizens with no 
known affiliation; public interest groups; municipal offi- 
cials and associations; federal officials; industrial/ 
commercial waste generators and the waste management 
industry. 

In varying degrees, consensus emerged in a variety of 
broadly-based areas as the product of collective public 
advice to both the Province of Ontario and the Ontario 
Ministry of the Environment. A summary of the collective 
public advice on municipal waste management is as follows: 

A Provincial environmental strategy is needed that 

incorporates municipal solid waste as one component of 
a comprehensive plan. 

An aggressive waste management education program is 
needed that targets a wide range of audiences and 
focuses primarily on effective ways to divert waste 
from disposal. 

° The environmental assessment and Ministry approvals 

process must be streamlined to enable the development 
of waste management facilities to keep pace with the 
need. 

° A provincial waste abatement strategy is needed that 
outlines precisely how Ontario will achieve the waste 
diversion targets. 

° A new emphasis is needed on waste diversion from 

disposal through accelerated waste reduction and reuse 
initiatives, particularly applied towards product 
manufacturers, the packaging industry and the 
industrial/commercial/institutional waste generators. 

° The full cost of waste management should be accounted 
for as a matter of routine and reported to the public. 

° Tire tax revenues should be applied exclusively towards 
a waste tire management solution. 

° Comprehensive waste management planning should be 
undertaken in all areas of Ontario. 

° Waste management responsibility and authority should be 
clarified by amending municipal legislation and giving 
municipalit. ^s explicit powers currently assumed by the 
province, particularly in the area of 3Rs . 



Ill 



Regulation 309 Municipal should be amended to clarify 
landfill site operating criteria and upgrade sites 
where necessary, to comply with new standards. 

The Ontario Government and Ministry of Environment 
positions are needed on energy from waste. 



1.0 INTRODUCTION 

The purpose of this report is to summarize the comments and 
advice given to the Ministry arising from the public 
consultation program on municipal solid waste management. 
Summary advice and feedback includes the public comments 
derived from all external sources including correspondence 
received by the Ministry, dialogue arising from meetings 
with a variety of individuals, groups and associations as 
well as selected newspaper reporting. A separate open file 
report is also available for central reference that contains 
the full text of correspondence and open discussion arising 
from staff presentations. 

The goal of the public consultation program was to hear the 
public's ideas and concerns about the current waste 
management system in order that a consensus could be reached 
for improvements during the decade ahead. The Ministry 
sought comments from the public to help determine future 
waste management policy and direction. In support of the 
public consultation goal, efforts were made to provide the 
public with information upon request, on all of the current 
Ontario Government supported waste management initiatives, 
programs, policies and legislation. 

2.0 PUBLIC CONSULTATION METHODOLOGY 

The public consultation program was designed to provide 
opportunities for open dialogue with key stakeholder groups 
who share an interest in the future of waste management in 
Ontario. Waste Management Branch staff coordinated the 
program and responded to group invitations to make 
presentations, answer questions and to listen sensitively to 
the ideas and concerns expressed. 

An environmental consulting firm specializing in public 
consultations was retained to document all forms of public 
response and to prepare a summary report (Appendix A, "A 
Report on Public Consultation undertaken for the Ministry of 
Environment on its discussion paper: Towards a Sustainable 
Waste Management System , Perley and Hurley Ltd.) . The 
public consultation program was promoted province-wide and 
supported by many staff from Head Office Branches, Regional 
and District Offices who also share in the responsibility of 
delivering the Ministry's waste management programs. 

The primary tool used to elicit public response in the 
consultation program was the discussion paper entitled, 
"Towards a Sustainable Waste Management System." The 
discussion paper was prepared by Ministry of Environment 
staff in cooperation with other Ministries that are directly 
involved in various aspects of the Ontario Government waste 



management programs including the Ministries of Government 
Services, Natural Resources, Energy, Municipal Affairs, 
Industry, Trade and Technology, Northern Development and 
Mines and Treasury and Economics. 

The discussion paper outlines Ontario' s goal and the 
underlying principles of a sustainable waste management 
system. It also describes the role of each key stakeholder 
group, progress made to date towards achieving a sustainable 
system and offers a broad framework for discussion of 
options for the decade ahead. The four umbrella categories 
that are provided to support discussion on the decade ahead 
include planning, financial sustainability, the 3Rs of waste 
management and, treatment and disposal. 

The discussion paper was designed to act as a communications 
tool that serves as a framework for ongoing dialogue among 
concerned citizens, business, public interest groups and all 
levels of government about the future of waste management in 
Ontario. It was not intended to serve as a device that 
would constrain the boundaries of discussion or limit the 
scope of helpful advice. A central theme of the discussion 
paper is that the combined efforts of all , not just the 
Ontario Government but the general public, the private 
sector and all three levels of government are needed to 
create a sustainable waste management system. The discussion 
paper was intended to elicit the public's views on how best 
to achieve Ontario's goal by the combined efforts of all 
parties, not simply but most often focusing upon future 
changes to the Ontario Government's existing program, 
policies and legislation. 

The discussion paper was released to the public along with a 
news release on July 9, 1990 (see Appendix D) . The news 
release described some highlights of the discussion paper 
and offered Ministry staff assistance to groups interested 
in presentations on the concept of a sustainable waste 
management system. More than 1,200 copies of the discussion 
paper and news release were mailed directly to the press, 
interest groups, industry and trade associations as well as 
municipalities, provincial MPPs, federal MPs in Ontario and 
Environment Departments throughout Canada. Several hundred 
subsequent requests for copies of the discussion paper from 
interested parties were also satisfied by many of the 
Ministry's offices, throughout the duration of the public 
consultation program. 

Thirty presentations were made by Waste Management Branch 
staff to a wide variety of external groups who requested the 
opportunity to exchange their views directly (see Appendix 
E) . Widely publicized public forums included events at 
Windsor, North Bay, Sudbury, Thunder Bay and Scarborough. 



Meetings with public officials at the municipal level also 
included the City of Burlington, the Region of Hamilton- 
Wentworth, the Region of Waterloo and the Region of Niagara, 
as well as the Waste Management Committee for the 
Association of Municipalities of Ontario. Presentations 
were also made to a wide variety of interest groups 
including the Conservation Council of Ontario, Ontario Multi 
Material Recycling Inc., Ortech International, the Ontario 
Federation of Labour and It's Not Garbage, a coalition of 
community, labour, business and environmental groups. 

At the federal level presentations were made to the 
Departments of Environment as well as Energy Mines and 
Resources. Presentations were made to various key groups in 
the private sector including the Ontario Waste Management 
Association, Waste Management Inc., Dow Chemical, Price 
Daxion, Unilever Inc., General Motors of Canada, the 
Canadian Manufacturers Association and the Grocery Products 
Manufacturers of Canada. Generally, all of these groups 
were appreciative of the opportunity to participate in the 
public consultation program and emphasized their desire to 
receive feedback from the Ministry on the action arising 
from the public comments received. More than one hundred 
letters were received by the Ministry from a variety of 
sources including some of those mentioned above (see 
Appendix B) . 

3.0 SUMMARY OF PUBLIC COMMENTS 

Several hundred public comments were received by the 
Ministry regarding Ontario's waste management system, both 
in terms of today' s concerns as well as ideas for the 
future. The tone and frequency of each specific public 
comment expressed by a wide variety of individuals was 
highly variable. In an effort to distil the public comments 
into helpful guidance to the Ministry on the future 
priorities for municipal solid waste management, sources of 
each comment are identified where possible along .with an 
indication of the frequency where similar comments were 
received. 

3.1 Public Comment Source - Stakeholder Groups 

Concerns and ideas were made known to the Ministry 
throughout the public consultation program by direct 
dialogue with Waste Management Branch staff or by letter. 
Public comments are attributed where possible to one or more 
of six different sources. For example, public sector 
comments are separated into four categories; citizens, 
interest groups, municipal and federal. Private sector 
comments are separated into the remaining two categories; 



4 



industrial/commercial waste generators and the waste 
management industry. 

3.1.1 Public Sector 

Citizens - concerns and ideas attributable to individuals 
who wrote letters and/or spoke directly with Waste 
Management Branch staff and did not make known any 
particular group or employer affiliation. 

Interest Groups - concerns and ideas attributable to 
individuals representing a variety of interest groups who 
wrote letters and/or spoke directly with Waste Management 

Branch staff. 

Municipal - concerns and ideas attributable to individuals 
employed at the municipal level (ie. elected officials and 
bureaucrats) and/or members of municipal associations or 
individuals active in the waste management master planning 
process who wrote letters and/or spoke directly with Waste 
Management Branch staff. 

Federal - concerns and ideas attributable to individuals 
employed at the federal level (ie. bureaucrats with either 
the Departments of the Environment or Energy, Mines and 
Resources) who wrote letters and/or spoke directly with 
Waste Management Branch staff. 

3.1.2 Private Sector 

Industrial/Commercial Waste Generators - concerns and ideas 
attributable to individuals representing a company or 
association whose members companies generate municipal solid 
waste and who wrote letters or spoke directly with Waste 
Management Branch staff. 

Waste Management Industry - concerns and ideas attributable 
to individuals representing a company or association whose 
member companies manage (ie. collect, transport, transfer, 
recycle or dispose) municipal solid waste and who wrote 
letters and/or spoke directly with Waste Management Branch 
staff. 

3.2 Public Comment Type - Highlighted or General 

For data summary purposes, public comment types have been 
classified under two broad headings, highlighted or general. 
Highlighted Public Comments are a compilation of those 
comments expressed most frequently by all sectors of the 
public (see Appendix A, Executive Summary) and which 
appeared to capture the most broadly based public interest. 
To make this summary complete, General Public Comments are 



also summarized in order that all of the concerns and ideas 
are documented from the public consultation program as 
potentially useful advice in setting future waste management 
program priorities. 

3.2.1 Highlighted Public Comments 

Highlighted Public Comments are derived from the entire 
public consultation program and are extracted from the 
consultant's summary report (Appendix A). 

3.2.1.1 Municipal Solid Waste Management - General 

• Frustration with the lack of programs in achieving a 
sustainable waste management system was a constant theme 
throughout the consultation process. 

3.2.1.2 Waste Management Planning and Approvals 

• Overall, participants found the EA process to be time- 
consuming, frustrating, and generally unwieldy. Many 
called for legislative changes, particularly municipal 
participants. 

• Participants suggested that municipalities needed the 
statutory authority to collect revenues intended to 
facilitate waste management; to do hydrogeological 
studies on leaking dumps on private land and to gain 
access to private land to ascertain suitable sites for 
landfill facilities; to fine or ban polluters; and to 
conduct recycling activities. 

3.2.1.3 3Rs of Waste Management 

• Many participants suggested that the underlying 
assumptions in the discussion paper favoured disposal of 
waste in landfill over the 3Rs, and recycling over 
reduction or re-use. Participants tended to strongly 
favour an increased emphasis on reduction and re-use. 

• Generally, participants who expressed opinions tended to 
agree that Ontario should move to take the initiative on 
packaging. 

• Many participants suggested that the soft-drink industry 
benefits from disposal and is not paying enough for the 
wastes it generates. The soft-drink industry was viewed 
as a beneficiary that was not paying its share of 
disposing of its accumulating wastes. 

• Participants considered the Blue Box program to be 
generally beneficial and positive. Negative aspects were 



not generally considered to be critical problems, bat 
rather normal obstacles to the growth of a curbside 
recycling system. However, access to secondary material 
markets is a concern to northern and remote 
municipalities . 

• Participants who voiced an opinion overwhelmingly 
supported both central and home composting. 

• The Ministry of Environment was generally considered to 
be too timid in the management of discarded tires. A 
credibility problem was alleged as a result of the lack 
of Provincial action to control discarded tires despite 
the funds collected from the tire tax. The illegal 
dumping of tires was also highlighted as a problem for 
municipalities . 

3.2.1.4 Financial Sustainability 

• The concept of beneficiary pay was regarded with some 
confusion and scepticism. Taken as a whole, public: 
response favoured full cost accounting to aid a 
financially sustainable waste management system. 

• Participants typically suggested it would be unreasonable 
to charge householders per bag of garbage and suggested 
that such a policy would lead to illegal dumping. 

3.2.1.5 Treatment /Disposal 

• Many participants asked MOE to articulate current and 
future policy regarding EFW in Ontario. Participants 
were strongly for and also strongly against implementing 
energy from waste programs. No clear consensus emerged 
on this issue. 

3.2.1.6 Other 

• Provincial programs to control hazardous waste were 
generally viewed as inadequate. Participants commented 
that they would like to see more emphasis placed on 
controlling hazardous and toxic waste. Hazardous and 
liquid industrial wastes however, were beyond the scope 
of the public consultation program. 

3.2.2 General Public Comments 

• General Public Comments are presented in a series of 
tables that capture as completely as possible, a summary 
of all the concerns and ideas expressed throughout the 
duration of the public consultation program. An :.ndex of 
codes appear at the foot of each successive page as a 



common means of presenting the various qualifying remarks 
for each comment. Different alpha codes are employed to 
indicate the source (s) of each comment (ie. stakeholder 
groups expressing their concerns) and the frequency of 
each comment (ie. concerns expressed - occasional or 
repeatedly) . The index of codes appears as follows: 



STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 
A = Citizens D - Federal 

B - Interest Groups E - Ind/Com Generators 

C = Municipal F " Waste Management Industry 

CONCERNS EXPRESSED 

O-Occasional (once or twice) R - Repeatedly (three or more) 



GENERAL PUBLIC COMMENTS 



3.2.2.1 MUNICIPAL SOLID HASTE MANAGEMENT 
GENERAL 

Generic Concerns 



. Provincial environmental strategy 
needed that incorporates municipal 
solid waste management as one 
component 

. Ministry should develop waste 
management policy in concert with 
MISA and CAP programs 

. Ministry needs to resolve conflicting 
roles of protector, advisor and 
f under 

. Minister should issue statement of 
commitment to the principles 
outlined in the discussion paper 

. Scope of the public consultation 
exercise included MSW only and 
excluded hazardous and liquid 
industrial waste 

Education 
Target Groups: 

- students at all levels 

- consumers 

- industrial/commercial waste 
generators 

- product manufacturers 

- packaging industry 

How to Accomplish: 

- co-operation (Federal, Provincial, 
Municipal, Industrial) 

- cultural outreach to all of society 

- advice offered in languages besides 
English and French 

- product label system to identify 
environmental effects 

- tax incentives for internal 
education within industry 

- prepare documentary on myths and 
facts 

Suggested Subject Areas : 

- reduction/ reuse opportunities 

- disposables 

- keys to achieving diversion 
targets for all generators 

- products not to purchase 



PUBLIC SECTOR 


PRIVATE 
SECTOR 


A 


B 


C 


D 


E 


F 



























































R 












R 
R 
R 






R 
R 
R 









R 
R 




R 
R 


















O 







R 
R 
R 

R 











STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 


A - Citizens 


D - Federal 


B - Interest Groups 


E - Ind/Com Generators 


C = Municipal 


F - Waste Management Industry 


CONCERNS EXPRESSED 




O-Occasional (once or twice) 


R - Repeatedly {three or more) 



GENERAL PUBLIC COMMENTS 



Education 

Suggested Subject Areas: (continued) 

- changes in societal attitudes 

- international experience/lifestyle/ 
behaviour outside Canada 

- composting 

- purchasing options 

- choices associated with 3Rs, 
treatment and disposal 

- technologies (wet/dry material 
recovery, landfill, EFW, etc.) 

- household hazardous wastes 

(alternatives and management) 

- avoid the purchase of non-repairables 



PUBLIC SECTOR 



R 

O 

R 
R 
R 



R 



PRIVATE 
SECTOR 



STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 


A - citizens 


D - Federal 


B - Interest Groups 


E ■* Ind/Com Generators 


C = Municipal 


F - Waste Management Industry 


CONCERNS EXPRESSED 




0- Occasional {once or twice) 


R «= Repeatedly (three or more) 



10 



GENERAL PUBLIC COMMENTS 



3.2.2.2 WASTE MANAGEMENT PLANNING 

AND APPROVALS 
Public Expectations 



means to achieve balance among 
competing interests 
. means to achieving diversion 
targets 

means to provide framework for 
options choice 

means to design the system within 
geographical units 
means to dispel public fears about 
treatment /disposal 

Perception of Challenges 



disappointed that Province passes 

planning on to municipalities 

EA frightens proponents who wish 

to initiate undertakings 

fear future legislation will 

undermine current waste management 

master plans (WMMP) 

the WMMP process is not working 

the Ministry should no longer 

support the WMMP process 

lengthy delays in Ministry review 

Ministry comments on EA reviews 

aren' t helpful 

delays associated with EA process/ 

approvals costly 

changes in Ministry staff 

contribute to inconsistent EA 

reviews 

garbage crisis is a political 

problem, not technical 

MNR Class EA on timber management 

dismisses recycling 

municipalities have no control over 

private sector collection and disposal 

EA approval needed before lands 

can be expropriated 

member municipalities battle 

Regions over facility siting 

lawyers and consultants profiting 

by lengthy process 

lawyers and consultants are 

contributing to delays 



PUBLIC SECTOR 



R 
R 
R 


O 



o 





R 
R 

R 

R 

R 
O 
R 

O 
O 
O 








o 





PRIVATE 
SECTOR 








STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


- Federal 




B 


- Interest Groups 






E 


- Ind/Com Generators 




C 


- Municipal 






F 


- Waste Management Industry 


CONCERNS EXPRESSED 















— Occasional (once 


or 


twice) 


R 


- Repeatedly (three or 


more) 



11 



GENERAL PUBLIC COMMENTS 



WASTE MANAGEMENT PLANNING 
AND APPROVALS 



Perception of Challenges (cont'd) 
~ public unaware of current costs, 
backlash inevitable 

Suggestions for the Future 

. Ministry should plan beyond the year 

2000 
. All government initiatives should plan 

towards diversion targets 
. areas in Ontario without plans must 

proceed and develop 
, unorganized areas need to be addressed 
. planning must improve 
. Provincial waste management authority 

supported 
. eliminate EA Hearing Board 
. Province take responsibility to ensure 

decision based on consistent reviews 
. clarify waste management authority 

by amending the Municipal Act 

appropriately 
. explore other methods of site selection 
. supports public participation 
. make all legislation compatible (EA, EPA 

Planning Act, Municipal Act) 
. amend legislation to create level 

playing field for the private and public 

sector proponents 
. municipalities should share the 

responsibility of waste management 

with the private sector 
. Ministry's approval system needs an 

effective and efficient framework 
. Ministry staff attitudes don't 

support the principle of 

"timely facility development" 
. environmental interest groups should 

participate 
. counties should administer waste 

management program 
. export of Toronto's garbage to the 

north not supported 
. host community concept unacceptable 



PUBLIC SECTOR 





R 

O 
R 





o 




R 
R 



PRIVATE 
SECTOR 



O 

o 








STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


- Federal 




B 


- Interest Groups 






E 


■ Ind/Com Generators 




C 


= Municipal 






F 


■ Waste Management Industry 


CONCERNS EXPRESSED 















= Occasional (once 


or 


twice] 


R 


= Repeatedly (three or 


more) 



12 



GENERAL PUBLIC COMMENTS 



WASTE MANAGEMENT PLANNING 
AND APPROVALS 



Suggestions for the Future (cont'd) 

. host community concept favoured 
. support public participation and 

decision making 
. Regional Boards supported - 

representation from province, 

municipalities, industrial generators 

and the public 
. want to be consulted in streamlining 

EA process/approvals 
. Ministry needs more EA and Approvals 

Branch staff 
. Ministry needs guidelines for Approvals 

staff to ensure consistent external 

advice 
. Streamlining EA efforts greatest 

potential for cost savings 
. guidelines needed for waste management 

master planning 
. guidelines needed for facility site 

selection 
. guidelines needed for municipalities 

to deal with consultants 
. master planning checklist needed to 

assess ongoing progress 
. future legislative approach to 

planning not supported 



PUBLIC SECTOR 



B 



O 
R 



R 

R 


R 
R 


O 









PRIVATE 
SECTOR 



STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B ■= Interest Groups E - Ind/Com Generators 

C - Municipal F - Waste Management Industry 

CONCERNS EXPRESSED 

O - Occasional (once or twice) R - Repeatedly (three or more) 



13 



GENERAL PUBLIC COMMENTS 



3.2.2.3 3RS OF HASTE MANAGEMENT 



Product Manufacturers 

. Environmental Choice Program - 

- only program endorsing products 

- poorly publicized 

. eliminate misleading advertising 

(environmental friendly) 
. develop labels to identify environmental 

effects 
. manufacturers should take cradle to 

grave responsibility 
. manufacturers should contribute directly 

to facility development 
. manufacturers should develop reusable 

products 
. build recyclability into products 
. incentives for reusable products 
. incentives for use of secondary material 
. incentives for waste audits 
. incentives for companies to educate 

staff 
. incentives for companies to develop less 

wasteful products 
. force manufacturers to use secondary 

materials 
. ban hazardous products that have 

environmentally friendly substitutes 
. eliminate subsidies for virgin materials 
. phone books should be redesigned to be 

easily recyclable 
. tax new oil 

. tax products that are toxic 
. tax products to carry disposal costs 
. tire companies should be responsible 

for waste tires 
. paint companies should be responsible 

for waste paint 
. glossy paper should be the paper 

manufacturers' problem 
.R&D needed 

. caution on blanket bans of disposables 
. Province should promote repairability 
. establish product development criteria 

(all costs, repairability, durability, 

life expectancy) 



PUBLIC SECTOR 



B 



R 
R 



R 

O 

R 

R 
R 
R 
R 

O 

R 


O 

o 
o 





o 



R 
O 



PRIVATE 
SECTOR 



STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B - Interest Groups E = Ind/Com Generators 

C - Municipal F - Waste Management Industry 

CONCERNS EXPRESSED 

O - Occasional (once or twice) R = Repeatedly (three or more) 



14 



GENERAL PUBLIC COMMENTS 



3RS OF HASTE MANAGEMENT 



Packaging Industry 

. Province must show leadership 

. National Packaging Task. Force must 

move quickly 
. national standards needed 
. reduction target not ambitious enough 
. legislation needed quickly 
. taxation supported 
. taxation not supported 
. all packaging should be recyclable 
. redesign component belongs at 

conceptual stage 
. increase understanding of material life 

cycles 
. impact of packaging reduction on economy 

unknown 
. complicated by Free Trade Agreement, 

trade barrier potential 
. incentives for packaging industry 

needed 
. R 4 D needed 

Reduction and Reuse 

. Government should lead by example, 

(paper consumption and procurement 

policy) 
. Ministry not emphasizing reduction 

and reuse enough 
. deposit systems for pop bottles 
. deposit systems for all containers 
. standardize returnable pop bottles 
. ban non-reusable containers 
. reusable systems create local 

employment opportunities 
. single serving refillables not available 
. incentives to companies 

that use /manufacture refillables 
. Ministry create a waste reduction 

office 
. ban disposables/non reusables 
, mandatory waste audits 
. tax disposables 



PUBLIC SECTOR 


PRIVATE 






SECTOR 


A 


B 


C 


D 


E 


F 






R 








R 


R 


R 

R 

R 

R 

R 
R 























R 



R 
R 

















R 













R 



R 

R 
R 
R 









R 











STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B - Interest Groups E - Ind/Com Generators 

C - Municipal F - Waste Management Industry 



CONCERNS EXPRESSED 

O - Occasional (once or twice) 



R « Repeatedly (three or more) 



15 



GENERAL PUBLIC COMMENTS 



3RS OF WASTE MANAGEMENT 



Reduction and Reuse (cont'd) 

. establish consultative advisory 

committees on reduction 
. tax free newspapers and junk mail 
. caution against deposit systems 
. treat garbage as a resource 
. deposit systems on hazardous waste/ 

product containers 
. eliminate junk mail 
. garbage compactors should be standard 

in new homes 
. householders should use garburetors 

Generic Recycling 

. province-wide industrial recycling 

program 
. establish marketing board for all 

recycled materials 
. Fed/Prov governments need to develop 

markets 
. costs are high in the north, EFW more 

attractive 
. recycle all wood wastes 
. recycle concrete in all municipalities 
. more emphasis on plastics 
. revenue from tire tax should be applied 

to waste tires 
. return system, for large goods 
, MTO work with municipalities to accept 

clean fill for highway construction 

and contouring 
. household hazardous waste 

- costs are too high 

- improve collection opportunities 

- include small generators 

- manufacturers should contribute 
. offer of waste oil infrastructure 

assistance 
. emphasis lacking on demand side 

regulations 
. high comparative costs of some 

recycled products 



PUBLIC SECTOR 




R 



o 




R 



R 
O 
O 
R 

R 

O 



R 
R 
O 
R 



O 
O 



PRIVATE 
SECTOR 



O 
R 



STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B - interest Groups E m Ind/Com Generators 

C - Municipal F - Waste Management Industry 

CONCERNS EXPRESSED 

O - Occasional (once or twice) 



R - Repeatedly (three or more) 



16 



GENERAL PUBLIC COMMENTS 



3RS OF WASTE MANAGEMENT 



Generic Recycling (cont'd) 

. labour intensive and costly 
. need more recycling facilities 
. costs should be shared among all 

generators 
. responsibility rests with the 

waste generator 
. incentives for use of secondary 

materials 
. CARI should be empowered to expand 

their role 

Blue Box Recycling 

. expand aggressively by 1992 to rural 

areas, apartments and other communities 
. expand to include other materials 

including junk mail 
. mandatory source separation needed 
. OMMRI is self serving, no long term 

relief for municipalities 
. OMMRI and Ministry must involve 

municipalities in formulating future 

agreements 
. OMMRI allows industries to buy their 

way out 
. reduce contamination through careful 

collect ion/ sorting 

Composting 

. promote more aggressively {central and 

backyard) 
. central composting guideline needed asap 
. promote sludge composting where 

appropriate 
. backyard composter marketing 
. regulate central composting 
. want to be consulted on compost 

guidelines 



PUBLIC SECTOR 


PRIVATE 
SECTOR 


A 


B 


C 


D 


E 


F 






O 


R 















R 












R 

























R 
R 








R 


R 


R 
R 

R 




R 















R 









STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


= 


Federal 




B 


- Interest Groups 






E 


- 


Ind/Com Generators 




C 


- Municipal 






F 


■ 


Waste Management Industry 


CONCERNS EXPRESSED 

















• Occasional (once 


or 


twice) 


R 


10 


Repeatedly (three or 


more) 



17 



GENERAL PUBLIC COMMENTS 



3RS OF WASTE MANAGEMENT 



3R3 Generally 

. diversion targets are too ambitious 
. diversion targets are not ambitious 

enough 
. diversion targets should be broken down 

into a separate strategy for each of 

the 3Rs 
. economic incentives needed 
. caution on regulations to achieve 

diversion targets 
. diversion rates greater than 55-60% 

is not possible 
. resurrect the fourth R 
. R&D coordination needed 
. waste composition studies needed in all 

municipalities 
, Ministry resource allocation should 

reflect the hierarchy 
. financial assistance should be greater 

for the north 
. exploit 3Rs at apartments, restaurants, 

hotels, arenas 
. create a centre for 3Rs R&D 
. 3Rs progress undermined by creating 

excess landfill capacity 
. designate one agency for information 

management /dissemination 
. Federal government has a role to 

provide incentives 
. mandatory waste audit3 needed 
. incentives for waste audits needed 
. support development of codes of practice 



PUBLIC SECTOR 



B 



O 
O 



R 





o 





R 
R 
R 

O 


o 

R 



PRIVATE 
SECTOR 



O 







O 




STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


■ Citizens 






D 


= 


Federal 




B 


- Interest Groups 






E 


- 


Ind/Com Generators 




C 


— Municipal 






F 


- 


Waste Management Industry 


CONCERNS EXPRESSED 

















— Occasional (once 


or 


twice) 


R 


- 


Repeatedly (three or 


more) 



18 



GENERAL PUBLIC COMMENTS 



3.2.2.4 FINANCIAL SUSTAINABILITY 



Perceptions of Challenges 

. who pays how much towards full coat? 

(ICI/Residential generators and Product/ 

Packaging manufacturers) 
. no generic model for full costaccountrng 
. absence of economic incentives for waste 

reduction 
. residential rate payer bears the burden 

currently 
. convince tax payer they won't be paying 

twice 
. government financial institutions 

contribute to the problem 
. full cost recovery schemes will result 

in road side dumping 
. public distrust arising from the tire 

tax 
. impacts of diversion targets on the 

economy are unknown 
. role of private sector not developed 
. role of small businesses not developed 
. financial assurance from the government 

needed for facility closure, 

monitoring and mitigation 
. waste management costs should be 

borne by the waste generators 

Suggestions for the Future 

. implement full cost accounting/ recovery 
. develop generic model for full cost 

accounting 
. consult with private and public sectors 
. comprehensive long term planning is a 

precursor to full cost accounting and 

recovery schemes 
. public reporting is an essential 

component 
. ICI waste generators and Product/ 

Packaging manufacturers should 

contribute to facility development 
. apply tire tax towards waste tire 

management solution 



PUBLIC SECTOR 



R 
R 



R 
R 



R 
R 



R 


R 

R 



R 
R 



R 
R 

R 
R 



R 
R 



O 




o 



o 










o 
o 



PRIVATE 
SECTOR 



STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B = Interest Groups E - Ind/Com Generators 

C - Municipal F - Waste Management Industry 

CONCERNS EXPRESSED 

- Occasional (once or twice) R - Repeatedly {three or more) 



19 



GENERAL PUBLIC COMMENTS 



FINANCIAL SUITABILITY 



Suggestions for the Future (cont'd) 



. product manufacturers should pay true 

costs including environmental and 

packaging coats 
. apply lottery revenue to develop 

recycling facilities 
. all elements of the waste management 

system should be publicly owned and 

operated 
. consult private sector when developing 

full cost accounting methodology 
. Federal funds are not necessary for 

provincial, municipal or commercial 

initiatives 
. full cost accounting/ recovery eliminates 

the need for subsidies 
. remove price incentives for virgin 

materials 
. more financial support for central 

composting 
. municipalities continue to ensure 

authority and contract out components 

of MSW management 
. behavioural psychologists could 

contribute insights into optimum 

cost recovery schemes 
. price incentives for virgin materials 

should be removed 
. legislative action needed against 

illegal dumping 
. remove all government subsidies 

Tipping Fees 

. local disparities with public and 

private landfills 
. private landfill owners should pay a 

royalty to the municipality 
. tipping fees can drive away industry 
. taxpayers pay for private landfill 

profits 
. standardize requirement for all 

facilities 
. oppose establishment because of 

roadside dumping 



PUBLIC SECTOR 



R 
O 








PRIVATE 
SECTOR 



O 

o 



R 


R 



R 
R 











STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


- 


Federal 




B 


- Interest Groups 






E 


* 


Ind/Com Generators 




C 


- Municipal 






F 


!■ 


Waste Management Industry 


CONCERNS EXPRESSED 

















- Occasional (once 


or 


twice) 


R 


*= 


Repeatedly (three or 


more) 



20 



GENERAL PUBLIC COMMENTS 



FINANCIAL SUITABILITY 



Tipping Fees (cont'd) 

. establish minimum community size 

for tipping fee requirement 
. current landfill costs in most 

municipalities are artificially low 
. establish on the basis of waste 

composition 
. tipping fees often inflated to cover 

residential generators waste 

contribution 
. municipal and private haulers should be 

charged the same tipping fee 

Direct Pricing Schemes 

. favour pay per bag schemes 
. oppose pay per bag schemes 
. tax credits for use of blue boxes/ 

composters 
. favours scheme that uses garbage cans 

instead of bags 
. favours scheme only where recycling is 

available 
. tax incentives for reduction and 

recycling 
. pay per bag would need to be by weight, 

not volume 



PUBLIC SECTOR 



R 

R 




R 





R 
R 











PRIVATE 
SECTOR 



STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


- Federal 




B 


- Interest Groups 






E 


■ Ind/Com Generators 




C 


- Municipal 






F 


- Waste Management Industry 


CONCERNS EXPRESSED 















- Occasional (once 


or 


twice) 


R 


- Repeatedly (three or 


more) 



21 



GENERAL PUBLIC COMMENTS 



3.2.2.5 TREATMENT/DISPOSAL 



PUBLIC SECTOR 



Perceptions of Challenges 

. facilities should all be state of the 

art 
. MISA and CAP programs will result 

in more MSW 
. Ontario government position on EFW not 

clear 
. Ministry position on EFW not clear 
. current regulations pertaining to EFW 

are unreasonable 
. municipalities reluctant to make 

facility change applications until 

Reg. 309 is amended 
. delivery timing and substance of Reg 309 

amendments are unknown 
. scales required at many landfills 
. private landfills accept waste outside 

of the master plan boundary areas 
. responsibility of landfill impacts after 

25 years past closure undefined 
. past performance factor in C of A 

application not established 
. absence of policy on MSW transportation 

Suggestions for the Future 

. larger centralized facilities better 

than large number of small facilities 
. facilities should be owned/ operated 

by the private sector 
. eliminate privately owned facilities 
. support concept of front-end diversion 

requirements 
. Ontario government should fund and build 

material recovery facilities 
. Reg 309 needs updating municipally and 

industrially 
. EPA amendments should not prohibit 

building on/near old landfill sites 

after 25 years 
. Ministry should fund methane recovery 

process at landfills 
. post-closure period should be based on 

monitoring results 
. oppose incineration 





R 

R 
R 



R 

O 

O 

o 
o 



R 
O 


O 









PRIVATE 
SECTOR 








STAKEHOLDER GROUPS EXPRESSING THEIR CONCERNS 

A - Citizens D - Federal 

B - Interest Groups E - Ind/Com Generators 

C - Municipal F - Waste Management Industry 

CONCERNS EXPRESSED 

O - Occasional (once or twice) R - Repeatedly (three or more) 



22 



GENERAL PUBLIC COMMENTS 



TREATMENT/DISPOSAL 



Suggestions for the Future (cont'd) 



ban all incineration 

Ministry of Energy should not provide 

capital support for EFW 

call EFW incineration 

support EFW 

cement kilns should be used to burn used 

tires 

promote RSD opportunities 

RfiD instead of regulations and 

enforcement 

include Federal R&D opportunities 

through the NRC 

designate one agency for information 

management /dissemination 

supports past performance as criteria 

for C of A approval 

supports Reg 309 amendment proposals 

supports private ownership/operation 

of facilities 

supports the concept of developing and 

sharing industrial codes of practice 

caution in linking C of A requirements 

to diversion targets 

concerns about landfill buffer zones 

need design and operating requirements 

for mobile leachate treatment and 

landfill gas management system 

consult waste management industry and 

utilize their expertise in solving 

treatment problems 



PUBLIC SECTOR 



R 
R 
R 



O 
O 







PRIVATE 
SECTOR 



O 
O 



O 





STAKEHOLDER GROUPS EXPRESSING 


THEIR CONCERNS 




A 


- Citizens 






D 


» Federal 




B 


- Interest Groups 






E 


« Ind/Com Generators 




C 


- Municipal 






F 


- Waste Management Industry 


CONCERNS EXPRESSED 















- Occasional (once 


or 


twice) 


R 


■■ Repeatedly (three or 


more) 



23 



3.2.3 Media Reporting 

Newspaper coverage of the July 9, 1990 discussion paper 
release was widespread in Ontario (see Appendix C) . 
Generally, the print media emphasized full cost recovery in 
their reporting of the Ministry's effort to consult with the 
public. More specifically, direct pricing schemes such as 
residential charge-per-bag cost recovery options were 
emphasized. The narrow emphasis of this newspaper coverage 
resulted in some public backlash in the form of Ministry 
correspondence from householders who considered that they 
were being unfairly victimized when compared with product 
manufacturers, the packaging industry and 
industrial/commercial/institutional waste generators. 

Extensive radio and/or television interview coverage was 
also provided at the public forum events at Windsor, 
Sudbury, North Bay, Thunder Bay and Scarborough. This media 
coverage was generally more balanced and reflected a fair 
assessment of the goal and scope of the public consultation 
program. 

4.0 CONCLUSIONS 

The goal of the public consultation program was to hear the 
public's ideas and concerns about the current waste 
management system in order that a consensus could be reached 
for improvements during the decade ahead. Ontario's goal 
and the underlying principles of a sustainable waste 
management system were not challenged by any of the program 
participants. 

In varying degrees, consensus emerged in a variety of 
broadly-based areas as the product of collective public 
advice to both the Province of Ontario and the Ontario 
Ministry of Environment . 

• A Provincial environmental strategy is needed that 
incorporates municipal solid waste as one component of a 
comprehensive plan. 

• An aggressive waste management education program is 
needed that targets a wide range of audiences and focuses 
primarily on effective ways to divert waste from 
disposal. 

• The environmental assessment and Ministry approvals 
process must be streamlined to enable the development of 
waste management facilities to keep pace with the need. 

• A provincial waste abatement strategy is needed that 
outlines precisely how Ontario will achieve the waste 
diversion targets. 



24 



• A new emphasis is needed on waste diversion from disposal 
through accelerated waste reduction and reuse 
initiatives, particularly applied towards product 
manufacturers, the packaging industry and the 
industrial/commercial/institutional waste generators. 

• The full cost of waste management should be accounted for 
by municipalities as a matter of routine and reported to 
the public. 

• Tire tax revenues should be applied exclusively towards a 
waste tire management solution. 

• Comprehensive waste management planning should be 
undertaken in all areas of Ontario. 

• Waste management authority should be clarified by 
amending the Municipal Act and giving municipalities 
explicit powers currently assumed by the province, 
particularly in the area of 3Rs. 

• Regulation 309 Municipal should be amended to clarify 
landfill site operating criteria and upgrade sites where 
necessary, to comply with new standards. 

• The Ontario Government and Ministry of Environment 
positions are needed on energy from waste. 



APPENDIX A 

A Report on Public 
Consultation 

undertaken for the 

Ministry of the Environment 

on its discussion paper 

Towards a Sustainable 
Waste Management System 

Per ley and Hurley Ltd. 



A REPORT ON PUBLIC CONSULTATION 
UNDERTAKEN FOR THE MINISTRY OF THE ENVIRONMENT 

ON ITS DISCUSSION PAPER: 
TOWARDS A SUSTAINABLE WASTE MANAGEMENT SYSTEM 



Perley & Hurley Ltd. 

November 30, 1990 



TABLE OF CONTENTS 

Page 
EXECUTIVE SUMMARY i 

I. INTRODUCTION 1 

II. METHODOLOGY 3 

III. PUBLIC RESPONSE BY SECTOR 5 
1.0 MUNICIPALITIES 

1.1 Elected Officials and the Municipal Public 6 

Service 

2.0 PRIVATE SECTOR 

2.1 Waste Management Industry 8 

2.2 Industrial/Commercial/Institutional Waste 9 
Generators 

3.0 GENERAL PUBLIC 

3.1 Interest Groups 10 

3.2 Residential Waste Generators (private 12 
citizens) 

4.0 FEDERAL GOVERNMENT 

4.1 Elected Officials and the Federal Public 13 

Service 

5.0 PROVINCIAL GOVERNMENT 

5.1 Elected Officials and the Provincial Public 14 

Service 



TABLE OF CONTENTS CONT. 

IV. PUBLIC RESPONSE BY SPECIFIC ISSUE 15 

o Financial Sustainability, 

Full Cost Accounting and Beneficiary Pay 15 

o A Surcharge Per Bag of Garbage 16 

o Tire Recycling 17 

o Refillable Containers in the Soft-Drink Industry 18 

o Disparities in Tipping Fees Across Ontario 19 

o Excess Packaging 20 

o Provincial Leadership in Waste Management 21 

o Recycling versus Reduction and Re-use 22 

o Assumptions in the Discussion Paper 23 

o Dumping of Garbage on Private Property 24 

o Centralized Composting and Home Composting 24 

o Energy From Waste Programs and Incineration 25 

o The Blue Box Program 26 

o Proposals for New Legislation 27 

o Hazardous Waste 28 

o Environmental Assessment 28 

o Method Used in the Public Consultation Process 29 

o Education 30 

V. CONCLUSION 31 



TABLE OF CONTENTS CONT. 



APPENDICES 

APPENDIX A. Glossary of Abbreviated Terms Used in the Text 

APPENDIX B. Description of Data 

APPENDIX C. Meetings Attended with Sectors/Tone of Meetings 



EXECUTIVE SUMMARY 

Participants indicated that they appreciated MOE seeking 
their views on waste management and that the consultation process 
was a worthwhile exercise if. comments made by participants were 
considered by MOE in setting future policy on waste management. 
They expressed diverse views on many waste management and 
environmental issues. The following highlights represent 
comments received from all sectors of the public. 

o Overall, participants found the EA process to be time- 
consuming, frustrating, and generally unwieldy. Many 
called for legislative changes, particularly municipal 
participants . 

o Provincial programs to control hazardous waste were 

generally viewed as inadequate. Participants commented 
that they would like to see more emphasis placed on 
controlling hazardous and toxic waste. 

© Participants suggested that municipalities needed the 
statutory authority to collect revenues intended to 
facilitate waste management; to do hydrogeological 
studies on leaking dumps on private land and to gain 
access to private land to ascertain suitable sites for 
landfill facilities; to fine or ban polluters; and to 
conduct recycling activities. 

o Participants considered the Blue Box program to be 

generally beneficial and positive. Negative aspects 
were not generally considered to be critical problems, 
but rather normal obstacles to the growth of a curbside 
recycling system. 

o Many participants asked MOE to articulate current and 
future policy regarding EFW in Ontario. Participants 
were strongly for and also strongly against 
implementing EFW programs. No clear consensus emerged 
on this issue. 

o Participants who voiced an opinion overwhelmingly 
supported both central and home composting. 

o Many participants suggested that the underlying 

assumptions in the discussion paper favoured disposal 
of waste in landfill over the 3Rs, and recycling over 
reduction or re-use. Participants tended to strongly 
favour an increased emphasis on reduction and re-use. 

° Generally, participants who expressed opinions tended 
to agree that Ontario should move to take the 
initiative on packaging. 



(ii) 



Many participants suggested that the soft-drink 
industry benefits from disposal and is not paying for 
the wastes it generates. The soft-drink industry was 
viewed as a beneficiary that was not paying its share 
of disposing of its accumulating wastes. 

MOE was generally considered to be too timid in the 
management of discarded tires. A credibility problem 
was alleged as a result of the lack of Provincial 
action to control discarded tires despite the funds 
collected from the tire tax. The illegal dumping of 
tires was also highlighted as a problem for 
municipalities . 

Participants typically suggested it would be 
unreasonable to charge householders per bag of garbage 
and suggested that such a policy would lead to illegal 
dumping . 

The concept of beneficiary pay was regarded with some 
confusion and skepticism. Taken as a whole, public 
response favoured full cost accounting to aid a 
financially sustainable waste management system. 

Frustration with the lack of progress in achieving a 
sustainable waste management system was a constant 
theme throughout the consultation process. 



I . INTRODUCTION 

The purpose of this report is to present the results 
obtained from the public consultation process undertaken for the 
Towards a Sustainable Waste Management System (TSWMS) discussion 
paper. It should be noted that this report was intentionally 
prepared in a format which would be easily accessible to members 
of the general public unfamiliar with waste management issues. 

The TSWMS discussion paper provided an overview of current 
MOE programs in the waste management area, and discussed how the 
MOE can promote sustainable waste management practices in Ontario 
in the future. As described in the discussion paper (TSWMS, 9), 
a sustainable waste management system would entail four primary 
goals : 

o REDUCED RELIANCE ON DISPOSAL 

Through an increased emphasis on the 3Rs (reduction, 
re-use and recycling) waste quantities would decline 
significantly. The 3Rs can reduce the need to dispose 
of waste material in landfill. 

o ENVIRONMENTALLY SECURE HASTE MANAGEMENT FACILITIES 

Waste management facilities in Ontario must meet strict 
environmental standards to ensure the protection of 
human health and the environment. 



o TIMELY FACILITY DEVELOPMENT 

Forecasting, planning and streamlining of the approvals 
process will speed the delivery of necessary waste 
management facilities. Innovative ideas are encouraged 
in order to stimulate applicable technologies. 

o FINANCIAL SUSTAINABILITY 

The full cost of waste management must be accounted for 
and recognized when recovering costs from waste 
producers. Current pricing practices which encourage 
the production of waste must be reduced or eliminated. 

Major new directions considered in the TSWMS discussion 
paper to further these goals included: increased efforts to 
promote the 3Rs, full-cost-accounting to ensure that the full 
costs of waste management are recovered from the beneficiaries of 
waste disposal, and tougher landfill standards. 



The principles endorsed by the discussion paper to further 
the above primary goals in the decade ahead (TSWMS, 22-33) 
included: 



PLANNING 

Comprehensive long-term planning throughout Ontario 
would allow all parties to participate in the 
resolution of their waste management challenges. 



FINANCIAL SUSTAINABILITY 

Elimination of imbalances in the current system of 
financing waste management activities. Waste 
generators and beneficiaries of waste management would 
pay the full cost of the management of wastes. 



THE 3RS OF HASTE MANAGEMENT 

Waste diversion targets would be pursued through 
additional 3Rs initiatives. 



o TREATMENT AND DISPOSAL 

Consistent, technically defensible standards would be 
utilized to ensure that existing and new facilities are 
maintained at a high level of environmental 
performance . 

The TSWMS discussion paper stated that the MOE is committed 
to a "policy of public consultation on important environmental 
matters that affect Ontario residents" (TSWMS, 38) . The Ontario 
Government has solicited comments and supported a broad-based 
dialogue with the public, industry, and all levels of government 
on the waste management issues raised in the discussion paper. 



II. METHODOLOGY 

The public consultation undertaken by MOE used as a basis 
for discussion the TSWMS discussion paper, prepared "as a 
framework for the ongoing dialogue involving concerned citizens, 
business, public interest groups and all levels of government 
about the future of waste management in Ontario" (TSWMS, 3) . The 
public consultation process was designed A) to further the 
Ontario Government's principle of public consultation on 
environmental issues of concern to Ontario residents, B) to 
foster an understanding of the challenging waste management 
issues facing Ontario today, and C) to move towards a consensus 
on the principles necessary to address those issues. 

The following steps were taken in the public consultation 
process for the TSWMS discussion paper: 

o A press release calling for comments from the 

public on the ideas in the paper was circulated by 
the MOE after the release of the discussion paper 
on July 9, 1990. Interested groups were invited 
to contact the Ministry and to organize meetings 
on their own initiative. Ministry staff, upon 
invitation from these groups, attended meetings, 
made presentations and answered questions. 

o To further publicize the release of the 

discussion paper, a mailing list of interest 
groups, municipalities, commercial and 
industrial associations and other governments 
was compiled. Copies of the discussion paper 
were circulated to more than 1,500 interested 
parties. 

o Ministry staff from the regions and 
districts, Environmental Assessment, 
Approvals and Waste Management Branches of 
the MOE were briefed during a series of 
presentations by MOE's Waste Management 
Branch staff. Ministry staff were informed 
of the content of the discussion paper and 
public consultation process. 

o a video tape and 35mm slides were prepared to 
present the ideas in the discussion paper to 
meetings with interested groups . 

o A French version of the discussion paper was 
made available to the public. Bilingual MOE 
staff were designated as contacts for 
bilingual residents of Ontario. 



o MOE staff began making presentations to 
interested groups September 4, 1990. 

o An environmental consulting firm, Perley & 
Hurley Ltd., was retained to document all 
forms of public response, and to prepare a 
report summarizing public response to the 
discussion paper at the conclusion of the 
public consultation period. 

Oral responses at meetings were received from individuals 
affiliated with interest groups, service clubs and associations, 
municipal government and industry, as well as from private 
citizens with no designated affiliation. Membership in a 
sectoral group was assumed if comments were recorded at a meeting 
held with a particular group (eg. comments recorded at meetings 
with municipal groups or environmental interest groups were 
attributed to members of those groups) unless individuals 
volunteered that they were in fact members of a different 
sectoral group. 

It should be noted that although the discussion paper raised 
broad philosophical and conceptual ideas for consideration, 
comments typically were directed to specific problems perceived 
and solutions to those problems. This limitation must be taken 
into account when drawing conclusions from the data received. 

It should also be noted that the presentations made to each 
group varied in content, format and length. For example, at a 
meeting in Ottawa an atypical presentation was made in which the 
headings 3Rs, Financial Sustainability, Planning, and Treatment 
and Disposal were each followed by a question period. The size 
of the group in this case allowed for a less formal exchange of 
ideas and the audience demonstrated a comparitively high level of 
interest. For all external presentations however, a common set 
of 35 mm slides were shown to ensure the delivery of consistent 
information about municipal solid waste management in Ontario. 



HI. PUBLIC RESPONSE BY SECTOR 

Concerns were expressed either in meetings with MOE staff or 
in writing. Five principal sectors responded to MOE's call for 
comments on the TSWMS discussion paper during the public 
consultation period. These sectors included: 

1.0 MUNICIPALITIES 

1.1 Elected Officials and the Municipal 
Public Service. 

2.0 PRIVATE SECTOR 

2.1 Waste Management Industry 

2.2 Industrial/Commercial/Institutional 
Waste Generators 

3.0 GENERAL PUBLIC 

3.1 Interest Groups 

3.2 Residential Waste Generators 

(private citizens) 

4.0 FEDERAL GOVERNMENT 

4.1 Elected Officials and the Federal 
Public Service 

5.0 PROVINCIAL GOVERNMENT 

5.1 Elected Officials and the 
Provincial Public Service 



6 

1.0 MUNICIPALITIES 

1.1 Elected Officials and the Municipal Public Service 

The concerns raised by municipal groups were numerous and 
also highly variable. However, several themes were of great 
concern to municipalities. They tended to concentrate heavily on 
perceived problems raised by the environmental assessment of 
landfill sites. Legislative changes to streamline EA procedures 
were felt to be necessary. Statutory authority over waste within 
municipal jurisdictions and statutory authority to conduct 
recycling programs were advocated. Energy From Waste (EFW) was 
advocated by many northern municipalities as an essential 
component of a comprehensive sustainable waste system. _ Packaging 
was considered a primary source of waste that was outside the 
jurisdiction of municipalities. Urgent Provincial and Federal 
action on this front was felt to be essential. 

Many municipal participants felt that the MOE and the 
Province were inadequately fulfilling financial, regulatory and 
administrative responsibilities. Municipal participants 
complained of a lack of effective Provincial leadership and 
initiative on contentious waste management issues. Some also 
criticized the Province for contradictory messages from different 
ministries and from within MOE. MOE's Approvals Branch was 
criticized for a perceived lack of clarity of direction on EA 
issues . 

Tipping fees at landfills were a source of concern to many. 
Several asked whether standardized tipping fees were planned, and 
pointed to problems with a public and private tipping fee 
structure in place. Opinion was divided as to the best approach 
to tipping fees. All who commented on this issue stated that 
they were a necessity, although many thought that at present the 
fee levels were too low. 

The Blue Box was commended, but participants complained that 
municipal costs were not fully supported by the Province or 
Ontario Multi-Material Recycling Inc. (OMMRI) and that costs had 
been shifted to municipalities from the Province. OMMRI was 
regarded as a vehicle which shifted costs from beverage 
manufacturers to municipalities. Refillable containers for soft- 
drinks were advocated by many and concern was voiced that MOE was 
not advocating reduction and re-use adequately in this context. 

The illegal dumping of hazardous wastes and tires was a of 
considerable concern to municipalities. They were generally 
quite frustrated with the progress made to date on these issues 
and advocated returning these waste materials to manufacturers. 
Some participants advocated regulating the production of products 
containing hazardous or toxic materials. Composting was 
supported by many as an ideal method to cut down on the volume 



and costs of landfill operations. 

Overall, municipal participants were critical of MOE r s 
record in the past. They were supportive of the principles and 
goal of a sustainable waste management system, but were 
frustrated by the rate of progress towards these ends and desired 
quick action in the future on some of the problems described 
above . 



8 

2.0 PRIVATE SECTOR 

2.1 Haste Management Industry 

Only one submission was received from the waste management 
industry. However, it enthusiastically supported the concept of 
sustainable waste management based on full cost recovery, and the 
use of market forces to support the 3Rs. Reduction of the 
current reliance on disposal, and financial and technical 
assistance from the Province to the waste management industry, 
were advocated. It was suggested that financial assistance could 
come from taxes on the use of raw materials or disposal. 
Additional suggestions included increased educational efforts to 
influence public attitudes in favour of conservation rather than 
consumption, and improved mechanisms to disseminate vital 
information on waste management to those sectors most in need of 
it. An inter-disciplinary research institution was advocated as 
a necessary instrument in the development and articulation of new 
innovations needed for government action on the environment. 
Generally, market forces were seen as possessing the potential to 
be a vital force in protecting the environment. 



9 
2.2 Industrial/Commercial/Institutional Waste Generators 

Industrial, commercial and institutional waste generators 
found the principles of a sustainable waste management system as 
articulated in the TSWMS discussion paper to be progressive and 
positive. Comments from this sector were not numerous, and a 
possible explanation can be found in one participant's opinion 
that comments at this time were premature in the absence of firm 
Provincial proposals concerning the specific measures to be 
employed to set up a sustainable waste management system. 

This sector suggested that far-reaching attitudinal changes 
were required to produce real reductions in waste. Education was 
advocated to that end and this was regarded as the responsibility 
of government with the input of the private sector. The 3Rs and 
composting were consistently supported as preferable to disposal. 
One participant noted that the cradle-to-grave responsibility 
that some manufacturers had already adopted satisfied many of the 
commitments required by a sustainable waste management system. 
This approach considers the entire "life-cycle" of a product, and 
some participants stressed that this approach was of fundamental 
importance and that the waste stream contains valuable resources. 
The Blue Box was praised as an important first step, and 
questions were asked about how well the program was accommodating 
waste materials picked up. 

The need for waste reduction at source, for the separation 
of waste at its source, and for a reduction in packaging was 
noted. The regulatory problem posed by the packaging used in 
imported goods was also pointed out. Uniform national measures 
were advocated, as well as the definition of "over-packaged" 
goods. Regulations designed to enforce deposit systems on 
beverage containers and to produce reduction and diversion of 
waste were not supported, and caution was recommended in these 
areas. Those who voiced an opinion supported EFW as a legitimate 
part of Ontario's total waste management plan. Overall, this 
sector's participation rate was sparse. Comments from this 
sector generally indicate support the TSWMS discussion paper's 
goals and the principles articulated to achieve them. 



10 

3.0 GENERAL PUBLIC 

3.1 Interest Groups 

Two types of interest groups are discussed under this sector 
heading: environmental groups and service clubs. 

Comments from one service club which made a presentation 
focused on whether the Blue Box program was adequately recycling 
material collected. Questions were also asked about the status 
of home composting programs. 

Environmental groups expressed concern that Provincial 
efforts to date to produce a sustainable waste management system 
were inadequate, and supported a far more aggressive approach to 
effect long-lasting change. Many expressed concern that the 
discussion paper favoured disposal over the 3Rs and did not 
contain detailed policies for solid waste management. Some 
participants advocated the use of recent figures from 1988 as a 
baseline year for waste diversion targets, and felt that 
diversion targets for waste could be more ambitious. Overall, 
participants regarded the discussion paper as a good starting 
point for discussion and action, but felt that more aggressive 
and comprehensive policies needed to be considered in the pursuit 
of a unified Provincial environmental strategy. Such a strategy 
would include existing programs such as MISA and the Clean Air 
Program. Several participants suggested that the Province was 
not showing leadership in passing on planning responsibilities to 
municipalities. The trans-shipment of solid waste across 
municipal jurisdictions was rejected by several participants. 

Environmental groups tended to agree with the concept of a 
sustainable waste management system and with full cost 
accounting. The Brundtland Commission Report was mentioned as a 
possible foundation for the concept of sustainable development. 
Some participants suggested that this approach could be furthered 
through financial incentives to manufacturers and purchasers of 
longer-use products, and disincentives to manufacturers and 
purchasers of disposable products. Increased funding for waste 
reduction and the creation of a "Waste Reduction Office" were 
suggested as important steps to demonstrate that the political 
will is present in Ontario to accomplish effective and long- 
lasting waste reduction. Mandatory source separation of 
recyclable materials and the storage of such materials until 
recycling facilities are erected were also advocated. Many 
participants voiced support for reduction and re-use before 
recycling. The Blue Box program was lauded, but increased 
efforts to process material recycled through the program were 
considered necessary. Participants who voiced an opinion 
rejected the inclusion of EFW facilities in Ontario as a part of 



11 

a sustainable waste system. EFW was generally regarded as a last 
resort after the 3Rs had been fully employed. 

In general, the discussion paper was criticized for not 
promoting new or truly innovative programs. Participants tended 
to feel that the Province could and should act more aggressively 
to reduce waste and implement programs to further the 3Rs . For a 
representation of specific comments please see Section IV. 



12 

3.2 Residential Waste Generators (Private Citizens) 

Residential waste generators (private citizens) raised many 
concerns and commented on varied aspects of waste management in 
Ontario. Comments tended to focus on problems of particular 
interest to private citizens, and some were unrelated to the 
broad themes raised for discussion by the TSWMS discussion paper. 
However, many comments pertained to aspects of sustainable waste 
management as covered in the discussion paper. 

Overall, private citizens were frustrated with what they 
perceived as a failure by Ontario to aggressively confront and 
solve problems in waste management. They frequently suggested 
that the Province was not moving fast enough to address pressing 
problems in waste management. The need for a deposit on soft- 
drink bottles and cans and perceptions that the soft-drink 
industry was not paying its share of the cost for waste 
management were recurrent themes. Frustration with the lack of 
progress in controlling excess packaging was strongly expressed 
by many participants; it was frequently suggested that government 
was being too timid in confronting industrial and commercial 
sectors on this issue. The vast majority of residential waste 
generators expressed negative reactions to proposals to institute 
a surcharge per bag of garbage for a variety of reasons . Many 
expressed the opinion that Ontario could and should act quickly 
and decisively to control discarded tires. Skepticism was voiced 
that the revenue generated from the $5 tire tax was being used to 
address problems in recycling tires. 

Support for the Blue Box program was widespread and 
extremely strong. Participants in municipalities that had not 
implemented Blue Box service were eager for their municipal 
officials to begin curbside collection. Some participants 
expressed the hope that household hazardous waste would be 
collected in the future. Participants asked whether progress was 
being made in finding markets for recycled materials and 
frequently asked for information on the status of the materials 
already gathered. Home and central composting were supported 
unanimously by those expressing an opinion. Educational programs 
in schools and among adults to support the 3Rs, particularly 
reduce and re-use, were also supported by those expressing an 
opinion. Some suggested that the underlying assumptions of 
waste management policy in Ontario tended to favour disposal over 
the 3Rs, and that disposal should be a last alternative after the 
potential in the 3Rs to divert waste from disposal was exhausted. 

Residential waste generators generally tended to express 
dissatisfaction with Provincial efforts to manage waste and 
suggested that strong and prompt action was necessary. For a 
representation of specific comments please see Section IV. 



4.0 FEDERAL GOVERNMENT 

4.1 Elected Officials and the Federal Public Service 

One of the most pressing concerns of the Federal Public 
Service was the impact that full cost accounting and beneficiary 
pay systems in support of a sustainable waste management system 
would have on taxation policy. It was stressed that in 
developing a sustainable waste management system, the waste 
management practises that are profitable should not be controlled 
by private industry, but should fund programs necessary to manage 
waste that can never be profitable. This sector also stressed 
the need to manage waste at the source of production and 
suggested that incentives to support the 3Rs were necessary (as 
opposed to disincentives applying to the production of products) . 
Sporadic discussion occurred concerning the need for definition 
of the type of education to best support 3Rs initiatives. 
Reduction and re-use were advocated as key principles to 
sustainable waste management. Some participants questioned what 
sort of government framework will be needed to foster new 
research and design innovations in products, and what would be 
the roles of Federal/Provincial negotiations and the National 
Packaging Protocol (NAPP) . 

One elected official commented that it would be beneficial 
to include the Liquor Control Board of Ontario (LCBO) in the 
debate over returnable containers . 

The process of public consultation undertaken by MOE was a 
subject of concern. Several participants raised questions 
concerning the role of public consultation and what Provincial 
action would result from the public consultation process 
undertaken for the TSWMS discussion paper. A few comments 
addressed the need to recycle newsprint and the need to be aware 
of behavioral changes produced through taxation. EFW was 
advocated as a needed element in waste management and the Not In 
My Back Yard (NIMBY) factor in this context was viewed as a 
negative element to be combatted. The possibility of legislation 
to change the role of municipalities was suggested to give them 
more authority over waste management within their jurisdiction. 
Please see Section IV. for a representation of specific concerns. 



14 

5.0 PROVINCIAL GOVERNMENT 

5.1 Elected Officials and the Provincial Public Service 

A brief submission from elected officials and the Provincial 
Public Service indicated that a comprehensive review of waste 
disposal sites in unorganized areas would be carried out by the 
Ministry of Natural Resources following the completion of the 
public consultation process for the TSWMS discussion paper. This 
review would emphasize further strengthening the 3Rs in 
unorganized areas. 



IV. PUBLIC RESPONSE BY SPECIFIC ISSUE 

While responses to the discussion paper have taken many 
forms, they have typically focused on a number of areas of 
concern. The eighteen concerns listed below were constant themes 
which arose during meetings in random order. The order of 
presentation below is not meant to suggest a hierarchical 
ranking. 



FINANCIAL SUSTAINABILITY, FULL COST ACCOUNTING AND BENEFICIARY 
PAY 

Participants raised questions on the meanings of the terms 
"financial sustainability, " "full cost accounting" and 
"beneficiary pay." Questions were raised as to the rationale 
behind coining phrases such as "beneficiary pay." Participants 
tended to assume that this phrase was merely a euphemism that 
avoided negative connotations for "user pay" systems. In this 
vein a representative concern was that "beneficiary pay looks a 
lot like user pay," and "I am not offended by the idea of user 
pay, but I am offended by the way this idea has been presented" 
(meeting, private citizen, 10/03/90) . The concept of beneficiary 
pay for waste management was considered by some to be pivotal "to 
enact behavioral change" (meeting, Federal Government sector, 
10/25/90) . 

The specific concept of sustainable development was not 
addressed at length by participants although many comments 
pertained to it. One participant did comment that forcing waste 
generators to "pay for the full cost of waste disposal is an 
important step towards a sustainable waste management system" 

(letter, private citizen, n.d.). Questions arose as to whether 
the use of the term "sustainable development" in the TSWMS 
discussion paper was "following the mold of the Brundtland 
Commission Report" (meeting, interest group, 10/03/90) . The 
discussion paper was criticized for not incorporating "some of 
the very basic system requirements of sustainable development 
contained in the Brundtland Report" (letter, private Citizen, 
10/26/90) . One participant commented that apart from sustainable 
development, "there is need for the similar emphasis on defining 
environmental sustainability" (letter, municipal sector, 
10/31/90) . The lack of any financial incentives to reduce waste 
in a system of sustainable development was mentioned as a problem 
in the TSWMS discussion paper, as was the possibility of 
environmental cost accounting being a type of "enviro-tax" 

(meeting, Federal Government sector, 10/25/90) which would be a 
disincentive to the development of new products. One participant 
felt that "financial disincentives should apply to disposable 
products" (letter, interest group, 10/31/90) . 



16 

Participants were generally very supportive of full cost 
accounting for waste management. The accounting mechanisms 
necessary to accomplish cost accounting were considered and the 
public acknowledgement of costs was lauded as an important first 
step in instituting systems of beneficiary pay. It was suggested 
that the public "will be much more willing to do that [public 
accounting] if it can be shown to them what that extra money is 
doing or going to do" (meeting, Federal Government sector, 
10/25/90) . Questions were raised about whether full cost 
accounting would assess long-term "environmental cost as well as 
economic costs" (meeting, municipal sector, 10/26/90) and it was 
asserted that "the costing system has been effective," (meeting, 
Federal Government sector, 10/25/90) as opposed to "fair" in 
assessing all costs. However, as one comment suggested, "in the 
final analysis, the cost system needs to be simple, easy to 
administer, and fair to the end user" (letter, municipal sector, 
10/31/90) . Taken as a whole, public response favoured a full 
cost accounting to aid a financially sustainable waste management 
system. The concept of beneficiary pay was regarded with some 
confusion and skepticism. 

A SURCHARGE PER RAG OF GARBAGE 

Many written submissions were received on this issue and 
participants were overwhelmingly against instituting a surcharge 
per bag of garbage. Although the need to institute a fair system 
of charging for waste management was widely acknowledged, this 
solution was not viewed as an acceptable method to address waste 
generation. Many comments suggested that "charging taxpayers 
directly for garbage removal... is bordering on stupidity" 
(letter, private citizen, n.d.) . The major reason cited was that 
a surcharge per bag would result in the illegal dumping and 
littering of garbage "in undesirable ways to avoid penalty or to 
benefit from the incentive" (letter, private citizen, 07/12/90) . 
Sporadic support was given to the surcharge per bag scheme, based 
on the necessity to force heavy generators to pay for their 
waste, with one participant commenting that "I feel that there is 
more immediacy in a pay-per-bag scheme... it might function as a 
greater incentive to reduce waste" (letter, private citizen, 
07/16/90) . However, such support for the surcharge per bag 
concept was infrequent, and it was generally regarded as an 
unfair tax that constituted "double charging" and "no solution to 
the problem at all" (letter, municipal sector, 08/02/90. One 
participant suggested that if the charge per bag was "credited 
back against the tax bills" it would indicate to citizens that 
they are not being doubly taxed" (meeting, Federal Government 
sector, 10/25/90) . As well, this participant felt that such an 
indication would change behaviour resulting in waste reduction. 

The link between excess packaging and the amount of garbage 
going to landfill was often pointed out and suggestions were made 



17 

to reduce packaging at source. The reduction of packaging was 
generally regarded as the responsibility of government and not 
the consumer. Government was also called on to "expand the Blue 
Box system" (letter, private citizen, 08/05/90) to accept more 
products, and to "start with the industries and their packaging 
of consumer goods" {petition bearing 29 signatures, private 
citizens, 08/20/90) . Government was also seen as slow to react 
to the problem of excess packaging or deal with the volume of 
packaging in a proactive and responsible way. 

Participants typically suggested it would be unreasonable to 
charge householders per bag. Many viewed it more reasonable to 
charge per volume or weight of waste as opposed to per bag in 
order to fairly address commercial, industrial and institutional 
waste generators. Finally, education was suggested as a better 
method of reducing waste than disincentives such as a charge per 
bag. 

TIRE RECYCLING 

One participant asked "where does the $5 per tire disposal 
fee go?" (letter, private citizen, 08/05/90) . The amount of 
money collected to date by the tire tax was of interest to many. 
Participants were highly resistant to the idea of putting revenue 
from the tire tax into general funds and often pointed to the 
lack of any visible improvements from the increased revenue 
generated by the tax: "you pay an extra $5 tax for your tires 
and yet we still have tire fires so we don't see a direct benefit 
from these extra costs" (meeting, Federal Government sector, 
10/25/90) . Another suggested that "the $5 tire tax be returned 
to the purchaser if he takes his tires back to the seller, who 
then would have to deal responsibly with them" (letter, municipal 
sector, 10/11/90). 

The tire tax was criticized as being the "wrong vehicle, 
what you should have is a regulation forcing tire companies to 
take back the product after use" (meeting, municipal sector, 
09/26/90) . The role of MOE in managing discarded tires was also 
criticized. Instead, it was advocated that manufacturers manage 
materials from "cradle-to-grave; " one participant stated that "it 
is more desirable to regulate and force tire companies to take 
back the product after use" (meeting, municipal sector, 
09/26/90) . 

MOE was generally considered to be "too timid and risk- 
averse" (meeting, municipal sector, 09/26/90) in the management 
of discarded tires, and a "credibility problem" (meeting, 
municipal sector, 10/03/90) was alleged as a result of the lack 
of Provincial action to control discarded tires despite the funds 
collected from the tire tax. The illegal dumping of tires was 
also mentioned as a difficult problem facing municipalities. 



18 

Incineration was seen as a possible solution to the problem of 
tire recycling; one participant pointed out that "the cement 
operators are very happy to help with this [incinerating tires] 
and have a very good process to do it" (meeting, Federal Public 
Service, 10/25/90) . 



REPILLABLE CONTAINERS IN THE SOFT-DRINK INDUSTRY 

Participants overwhelmingly supported refillable bottles and 
returnable cans and suggested that "we have to ban non-refundable 
bottles" (meeting, private citizen, 10/03/90) . Many participants 
commented that the Province has abdicated its responsibility to 
regulate soft-drink cans and bottles and that the soft-drink 
industry through OMMRI has "deflected the costs of materials 
rather than taking on the full responsibility" (meeting, private 
citizen, 10/11/90) . One participant commented that the economic 
costs to the community of non-returnable soft-drink containers 
"far exceeds the money that the city will ever receive from 
OMMRI," and complained that "if I want to buy a single serving of 
soft-drink in this community [in a recyclable container], how do 
I do it other than going into a restaurant and pouring it into a 
glass and sitting and drinking it?" (meeting, municipal sector, 
10/03/90). Several participants suggested that "the Brewer's 
Retail. . .deposit fee on a can" (meeting, private citizen, 
10/03/90) be used as a model for the soft-drink industry. It was 
also suggested that "the LCBO issue a deposit fee for any product 
they sell" (meeting, municipal sector, 10/03/90) . Alternatively, 
central recycling depots were suggested for soft-drink bottles 
and cans; one participant advocated "a big Blue Box" (meeting, 
private citizen, 10/01/90) in central locations. 

The Blue Box was sporadically criticized for allowing 
consumers to purchase soft-drink products and dispose of them 
without re-use. Participants suggested that many non-refillable 
containers end up as litter and not in Blue Boxes. Many 
participants suggested that the soft-drink industry benefits from 
disposal and is not paying for the wastes it generates: "clearly 
the beneficiary in this case is not just the consumer but also 
the pop and soft-drink industry [and] I did not see anywhere in 
there where you are going to be looking at getting those 
beneficiaries to pay for some portion of the vast wastes 
accumulating" (meeting, municipal sector, 10/26/90); and further: 
"MOE got the can producers to make a contribution to Blue Box, 
but the can producers made that contribution knowing that the 
costs of deposit containers would have been far more than $45 
million" (meeting, private citizen, 09/27/90) . These comments 
exemplify the powerful public support recorded for refillable 
containers . 



19 
DISPARITIES IN TIPPING FEES ACROSS ONTARIO 

Response among participants to tipping fee disparities was 
mixed. Some participants asked when tipping fees will "be 
standardized across the Province" (meeting, municipal sector, 
09/13/90), while others suggested that "what a public landfill 
takes to save for the future, a private one makes in profit" 

(meeting, municipal sector, 09/13/90) . Municipal participants 
also expressed concern that "we may get to the point where we 
can't service the industries in our municipalities and they may 
move to unorganized areas where their waste costs are less" 

(meeting, municipal sector, 09/27/90) . Computer models currently 
in use also tend to generate "a disappointingly low tipping fee" 

(meeting, municipal sector, 09/13/90) . Municipalities alleged 
that planning for tipping fees was complicated by unknown 
variables such as the fees at private sites. Participants 
pointed out that tipping fees for private landfill were not 
comparable to that of public landfills because municipalities 

"have programs in place. . .operating, capital, we have recycling 
programs that all come out of tipping fees," and that private 
landfills do not have "a Blue Box program to support, a 
composting program, [and] half a dozen decommissioned sites to 
maintain" (meeting, municipal sector, 10/15/90) . 

Participants also commented that current aspects of the 
Municipal Act make it difficult to finance municipal collection 
and disposal if waste is precluded from landfill as a result of 
an industry not separating waste components. Higher tipping fees 
were called political "hara-kiri" (meeting, municipal sector, 
10/30/90) in this instance, as industries had already paid taxes 
under the Municipal Act for collection and disposal. Current 
tipping fees were generally regarded as too low. Participants 
expected tipping fees to rise as landfill space was used up; one 
participant stated that "the last ton of garbage that comes in to 
landfill will probably be at $500 a ton" (meeting, municipal 
sector, 10/15/90) . 

Disparities in tipping fees were generally acknowledged by 
municipalities to be a major problem in waste management 
planning. One representative comment stated that "tipping fees 
should reflect the true cost of waste management and disposal 
services, that they should be uniform, that they cannot be hidden 
in municipal tax bills" (letter, municipal sector, 10/11/90) . 
Another participant corr^ented that "when a municipality has a 
$160 tipping fee like Halton has got and the next door one has a 
$75 one, stuff starts going all over the place" (meeting, 
municipal sector, 09/26/90) . These two concepts represent themes 
generally accepted by the general public with respect to tipping 
fees. 



EXCESS PACKAGING 

Participants expressed frustration at what they perceived as 
the slow rate of Provincial action to reduce excess packaging. 
Many participants believed that Ontario should act to "enforce 
packaging regulations at manufacturing source" {letter, private 
citizen, 08/05/90) . Provincial efforts to educate the public to 
enable it to choose less packaged products were regarded as an 
important first step by most participants, but this was not 
regarded as an adequate policy to address the problem of excess 
packaging: "it is the role of government to enforce strict 
regulations on packaging, and not the role of the public to avoid 
the purchase of over-packaged goods" (letter, private citizen, 
10/28/90) . 

The role of the NAPP was the subject of some questions, with 
many participants stating that they did not understand the 
structure of the protocol and mechanisms for enforcement of 
controls on packaging. NAPP was called "ambiguous. . .it doesn't 
really say anything" (meeting, private citizen, 10/03/90), and 
one participant asked "How does NAPP work? What kind of 
authority do they have to implement changes?" and "What clout is 
there to NAPP?" (meeting, municipal sector, 10/03/90) . A 
participant suggested that the effort to reduce packaging "has to 
be a dual responsibility, " and that "there are components of it 
[packaging controls] that have to be driven at the provincial 
level" (meeting, Federal Government sector, 10/25/90) . One 
comment at the Federal level suggested that NAPP was merely 
trying to "set out who has jurisdiction where" (meeting, Federal 
Government sector, 10/25/90) . 

Participants suggested that the provincial emphasis on 
packaging is misguided in that it only concentrates on the 
products at the "end of the pipe;" this proponent suggested 
shifting "the emphasis much higher up in the hierarchy, to the 
reduction and re-use side" (meeting, Federal Government sector, 
10/25/90) , instead of emphasizing the reduction of unneeded 
products before they are produced. Similarly, it was suggested 
that "incentives should be provided on the development or R & D 
phase of the energy as well as the industry development" 
(meeting, Federal Government sector, 10/25/90) . Increased 
support for R&D was felt to be a necessary step to reduce the 
production of packaging. Forcing packaging producers to use 
recycled products was advocated. Concern was expressed that 
packaging restrictions would make Canadian products more costly 
to produce and less competitive internationally, particularly vis 
a vis the United States: "all products that are determined to be 
less [environmentally friendly] will not be packaged or made in 
Canada, they will just go across the border" (meeting, Federal 
Government sector, 10/25/90) . 



Generally, participants who expressed opinions tended to 
agree with the statement that "my feeling is that the Province 
should take the initiative on packaging, my understanding is that 
the Province is not cooperating" (meeting, municipal sector, 
09/26/90) . 

PROVINCIAL LEADERSHIP IN WASTE MANAGEMENT 

Many participants asserted that the Province was not showing 
leadership in the waste management field. One commented that 
"government has been slow to come to terms with the crisis of 
growing waste" (letter, private citizen, 07/12/90), another that 
"maybe Ontario should show some leadership" (meeting, municipal 
sector, 09/26/90) . Other participants complained that the 
Province had passed planning responsibilities on to the 
municipalities: "The Province offers assistance to 
municipalities in terms of administrative procedures but does not 
put forward the substantive policy guidance which municipalities 
have requested" (letter, private citizen, 08/14/90) . The costs 
of waste management were alleged to have been shifted by the 
Province "from re-use to recycle and from the producer of the 
product to the consumer and from there to municipalities" 
(meeting, private citizen, 09/26/90) . 

Several participants complained that they had received 
contradictory messages from different ministries in Ontario, eg. 
from Municipal Affairs and Treasury: "we have one ministry 
saying 'no reserve funds' and the other saying you should 
establish reserve funds" (meeting, municipal sector, 10/30/90) . 
This lack of coordinated policy was also found coming "from 
different branches of MOE" (meeting, municipal sector, 09/27/90) . 

Many participants focused on the problems their 
municipalities had in landfill siting as a result of 
environmental assessment and attacked MOE for administrative 
delays in the environmental assessment process. Municipal 
participants generally felt frustrated by what they saw as a lack 
of firm guidelines for MOE policy and procedures, as one 
municipal participant claimed, "not only in solid waste but in 
water and sewer" (meeting, municipal sector, 10/30/90) . Several 
participants felt that the Province should act to license, 
regulate or ban products that are hazardous to the environment or 
that produce toxic waste after disposal in landfills; in short, 
"if you can't reverse the process and make the product safe you 
shouldn't be allowed to make the product" (meeting, municipal 
sector, 10/03/90) . One comment stressed that "waste management 
policies, if they are to be effective, must be considered in the 
context of a unified provincial environmental strategy" (letter, 
interest group, 10/31/90) which would include the Municipal and 
Industrial Strategy for Abatement (MISA) and the Clean Air 
Program (CAP) . 



22 

The Blue Box was often seen as a positive step towards the 
recycling of solid wastes, but the Province was also criticized 
for the slow rate of expansion to cover apartments and rural 
areas. The Blue Box was also criticized for shifting the 
emphasis from reduction and re-use to recycling. 

Several participants commented that the wide margins and 
wasted space in the design of the discussion paper made it a poor 
example of the principles articulated within it: "it's really 
quite funny how you can waste half the paper in a book yet claim 
that you want to become a- 'model waste manager'" (letter, private 
citizen, 08/28/90) . 

Frustration with the lack of progress in achieving a 
sustainable waste management system was a constant theme 
throughout the consultation process, with the refrains being: 
"can it happen sooner?" (meeting, interest group, 09/18/90), and 
"we are not moving fast enough" (meeting, municipal sector, 
09/26/90) . Many participants agreed that "the Province must play 
the lead role in implementing the solid waste management 
strategy" (letter, interest group, 10/31/90) . 

RECYCLING VERSUS REDUCTION AND RE-USE 

Many participants questioned whether the hierarchy of the 
3Rs was being observed by MOE in light of what they regarded as 
the over-reliance on the recycling of products rather than 
reduction and re-use: "the hierarchy is set out of reduction 
first, re-use second, recycle third. Is MOE still promoting 
recycling as the target or have they diverted from recycling to 
re-use or reduction as the #1 focus now?" (meeting, municipal 
sector, 10/15/90). The Blue Box's educational value was 
universally recognized, but many participants expressed positions 
suggesting that "there is a hierarchy of the 3Rs and recycling is 
number three of those" (meeting, private citizen, 09/27/90) . One 
participant pointed out that, unfortunately, the use of the Blue 
Box and concentration on recycling can be negative if it results 
in a complacent attitude: "that is wrong and I think the 
emphasis should be on re-use and the reduction of waste. The 
Province should be looking at ways of doing that" (meeting, 
municipal sector, 09/26/90) . Another also suggested that "what 
has happened is that there has been a shift of the costs of waste 
management ... from re-use to recycle" (meeting, municipal sector, 
09/26/90) . 

Participants tended to strongly favour an increased emphasis 
on reduction and re-use. Representative comments included: 
"emphatically 'yes' to the public on your intentions on the side 
of source reduction as part of the programming in future, it is 
something we have seen as being missing, even the political will" 
(meeting, municipal sector, 10/29/90), and "this committee's 



priority in the area of waste management is WASTE REDUCTION" 
(letter, municipal sector, 10/11/90) . 

ASSUMPTIONS IN THE DISCUSSION PAPER: DISPOSAL VERSUS THE 3RS 

Assumptions underlying the discussion paper, as well as 
issues and concepts which it omitted or did not emphasize, 
preoccupied some participants. The public's judgments on the 
basic assumptions in the discussion paper was mixed. One 
participant stated that "my main intention this evening in coming 
was to talk about what is not in the paper and that is the goal 
of transportation of waste" (meeting, interest group, 10/03/90) . 
Another participant stated that in his opinion a general theme in 
the discussion paper was that "there was a lot of emphasis put on 
landfill and we didn't focus as much on the upstream side, on the 
waste reduction, re-use, and recycle component of it" (meeting, 
Federal Government sector, 10/25/90) . Another participant 
commented that the discussion paper "gives a message that the 
hierarchy of the 3R' s in waste management is dealt with quickly 
and we move very quickly to that which is left over after we go 
through the hierarchy of the 3R's" (meeting, interest group, 
10/03/90) . This position was supported by several participants. 
One commented that "the discussion paper is a soft document, only 
designed to spur thought. The rhetoric in the document suggests 
that it is attempting a paradigm shift from landfill to 3Rs, 
however in the final analysis landfill is still emphasized over 
the 3Rs" (meeting, interest group, 10/26/90) . This was seconded 
by several other participants: "We would suggest that as the 
program now stands the emphasis is placed not on 'managing waste' 
but on finding a new piece of land in which to put garbage. We 
disagree with this emphasis" (letter, municipal sector, 
10/11/90); reduction was looked upon as "the key player in 
establishing a sustainable waste management system" (letter, 
10/25/90) . 

A further assumption in the discussion paper, allegedly 
implicit in MOE's policies in general and explicit in the 
discussion paper, was the following: "the paper fails to examine 
municipal solid waste management as a problem of economic 
structure and inefficient resource use" (letter, private citizen, 
08/14/90) . Concern that basic societal values favouring 
consumption over reduction were not examined in the discussion 
paper was voiced several times, one participant commenting that 
"we must reduce our use of raw materials and that means a simpler 
lifestyle" (meeting, private citizen, 10/01/90) . Several 
comments indicated that the discussion paper was "an articulate 
description of intent, but lacking as far as identifying the 
precise vehicles for reaching specific goals" (letter, private 
citizen, 10/10/90) . 



24 

Other participants generally found the approach of the 
discussion paper to be interesting and innovative: "in the main, 
we find this document to be comprehensive and balanced and 
reflecting views which we support" (letter, private sector, 
09/25/90), and further, "I am impressed by this report" (meeting, 
interest group, 09/26/90) . Another participant stated that "your 
discussion paper is heading in the right direction and is an 
excellent starting point" (letter, municipal sector, 10/11/90) . 
However, these views were in the minority. In general, 
participants who voiced an opinion on this issue tended to find 
that the underlying assumptions in the discussion paper favoured 
disposal of waste in landfill over the 3Rs, and recycling over 
reduction or re-use. 

THE DUMPING OF GARBAGE ON PRIVATE PROPERTY. 

This issue is closely linked with the public's reaction to 
the concept of charging per bag of garbage. Many participants 
warned that the inevitable reaction to a surcharge per bag was an 
increase in the illegal dumping of garbage. Representative 
comments include the following: if there is "a high direct 
pricing you will have subterfuge talcing place and fly-by-nighters 
or people who will go and dump their garbage" (meeting, Federal 
Government sector, 10/25/90), and "in rural areas we have 
television sets and washers and dryers on my property. I had a 
large pile of garbage put on my property on the weekend. This is 
a constant problem and it will get worse" (meeting, municipal 
sector, 09/26/90), and also "if you are a private property owner 
in a rural area you are finding you have other people's litter on 
your property. I am concerned especially about hazardous waste 
products" (meeting, municipal sector, 09/26/90) . These three 
comments exemplify the concern voiced in an overwhelming body of 
the comments received on this issue. 

CENTRALIZED COMPOSTING AND HOME COMPOSTING 

Participants generally tended to favour both centralized and 
home composting. In support of composting participants stated 
that "a composting plant of this sort is feasible and will work" 
(meeting, private citizen, 10/01/90), and "I have got a composter 
now and it has reduced my waste by close to 50%. Composting is 
the way to go" (meeting, private citizen, 10/01/90) . Several 
participants asked questions about the availability of backyard 
composters, eg. "what municipalities are currently offering 
backyard composters to their residents?" (meeting, interest 
group, 09/04/90) . 

Participants also raised questions about the timing of 
regulations or guidelines for composting, eg: "when will central 
composting guidelines be coming out?" (meeting, interest group, 



09/18/90), and "will the regulations for centralized composting 
be coming out this fall and will they be written in such a way 
that it will be easy for municipalities to set up a centralized 
composting system and make it easy to dispose of material?" 
(meeting, municipal sector, 09/26/90) . 

In general, participants who voiced an opinion 
overwhelmingly supported both central and home composting, one 
representative comment stated that "composting should be getting 
considerably more promotion and financial support" (letter, 
private citizen, 10/10/90) . 

ENERGY FROM WASTE (EFW) PROGRAMS AND INCINERATION 

The subject of EFW proved quite contentious. Many 
participants were strongly for EFW and many were equally strongly 
opposed to it. Those supporting EFW included small 
municipalities and Federal Government representatives. Municipal 
participants, especially in Northern Ontario, argued that "MOE's 
regulations for compliance appear unreasonable, this year I can't 
burn waste any more; that cuts my landfill capacity to seven 
years" (meeting, municipal sector, 09/14/90), and also "the 
weakness in Ontario's program is the lack of a meaningful Energy 
From Waste program. . .a much liberalized approach to Energy From 
Waste would substantially improve Ontario's plan and that it 
would be especially advantageous in our scattered Northern towns 
where recycling is difficult" (letter, municipal sector, 
08/01/90) . Federal participants suggested that EFW "is a very 
large and viable resource, a lot of the material we have got in 
our landfill site could be quality EFW material. Where is MOE 
coming down on that whole EFW issue?" (meeting, Federal 
Government sector, 10/25/90) . The private sector also tended to 
support "the recognition that energy from waste has a place in a 
total waste management master plan" (letter, private sector, 
09/25/90) . 

Contrarily, some participants claimed that EFW was 
dangerous. Private citizens and interest groups generally felt 
that "EFW does not solve the problem. I think also more 
dangerous is that it encourages production, " and "the term EFW 
gives rise to the feeling that we are getting something and that 
is tricking people" (meeting, interest group, 10/03/90) . Another 
participant was concerned that "the implementation of further 
incinerators in Ontario would completely undermine all of the 
programs outlined and promoted within this paper" (letter, 
private citizen, 10/23/90) . Further comments stressed "the 
potential risks involved in implementing EFW programs" (letter, 
private citizen, n.d.), and concluded that "the incinerator 
option should be last on the list" (letter, private citizen, 
10/29/90) . 



26 

Many participants asked MOE to articulate current and future 
policy regarding EFW in Ontario, and stated they were "confused 
as to what the current Ministry position is with respect to any 
form of incineration" (meeting, municipal sector, 10/29/90) . 
Opinion was clearly split in this sector of the public on the 
benefits of implementing EFW programs. 

THE BLUE BOX PROGRAM: POSITIVE AND NEGATIVE ASPECTS 

The Blue Box program was generally seen as a positive and 
progressive program. However, many participants suggested that 
the program should be expanded and that increased efficiency was 
desirable. One participant suggested that "the Blue Box program 
should be expanded to rural areas and apartments by 1992" 

(meeting, municipal sector, 09/27/90), another asked, "what is 
the hold up? Five years to achieve a one-third increase?" 

(letter, private citizen, 10/09/90) . It was also emphasized that 
Blue Box did not apply to industrial and commercial waste 
generators: "I applaud the effort of the Blue Boxes, but only 
20% of our landfill comes from residential stuff, what do you 
plan to do with stuff coming from commercial and industrial 
sources?" (meeting, private citizen, 10/11/90) . Residents in 
meetings held at two municipalities indicated that they supported 
Blue Box, but were frustrated with the slow progress in 
establishing municipal Blue Box service: "people now have their 
garages full of materials to be recycled and they have nothing to 
do with them, they are disappointed and disillusioned" (meeting, 
private citizen, 10/03/90) . 

Negative aspects mentioned were the perception that the 
"recycling of waste in Blue Boxes is positive, but people now 
feel quite comfortable throwing away a few cans and newspapers 
and they have done their thing for the environment and community" 
(meeting, municipal sector, 09/26/90), and that "the expansion of 
'blue box' activities makes little sense until markets for 
recovered materials are expanded or stabilized" (letter, private 
citizen, 08/14/90). QMMRI's role in funding the Blue Box was 
generally looked upon as an inadequate response to its obligation 
to foster the re-use of soft-drink cans and bottles. 

The question of what a "recyclable product" is was raised, 
as well as the difficulty in meeting material specifications and 
standards if more recycled content is included. Questions were 
also asked about the status of Ontario's newsprint recycling 
capacity. Some private citizens were concerned that the 
infrastructure necessary to process, ship, and sort materials 
recycled through Blue Box was not in place. Ontario was also 
criticized for lacking "an effective marketing strategy for 
selling the increasing volumes of recycled materials now being 
collected" (letter, private citizen, 10/22/90) . The Federal 
Environmental Choice program was frequently discussed and the 



27 

lack of Provincial programs to try "to impact product through 
which you can impact waste management" (meeting, Federal 
Government sector, 10/25/90) was cited as a need to be addressed. 

Overall, participants considered the Blue Box program 
beneficial and positive. Negative aspects were not generally 
considered to be critical problems but rather normal obstacles to 
the growth of a curbside recycling system. 

PROPOSALS FOR NEW LEGISLATION 

Many participants advocated new or revised legislation on 
taxation structures, excess packaging, controls over toxic 
products, and enforced recycling. Municipal participants 
suggested that planning was often difficult without statutory 
authority over waste within their jurisdiction and asked "how 
does it stand with the Ministry of Municipal Affairs on this 
statutory authority?" (meeting, municipal sector, 10/11/90) . The 
Environmental Assessment Act was frequently attacked as being in 
need of legislative revision. One participant asked, "is there 
an acknowledgement in Ontario that the Environmental Protection 
Act is not adequate to deal with what you want to do in the next 
five to ten years?" (meeting, Federal Government sector, 
10/25/90) . The lack of legislative controls on the producers 
of products was the subject of concern: "one of the things that 
comes to mind is to tax products that have toxic components to 
them, and the other one is to tax the disposal of products" 

(meeting, municipal sector, 09/26/90); and "how far away are we 
in terms of legislation against the companies, the producers and 
manufacturers?" (meeting, municipal sector, 10/15/90) . 
Participants further suggested legislation requiring that a 
percentage "of recycled wood pulp products go into all corrugated 
packaging" and "recycled plastic go into the manufacturing of all 
plastic containers, with the exception of food containers" 

(letter, private citizen, n.d.). 

Several participants suggested that municipalities needed 
the authority to collect revenues to facilitate waste management; 
to do "hydrogeological studies on leaking dumps on private land" 
(meeting, municipal sector, 09/13/90) ; to gain access to private 
land to ascertain if a site is suitable for a landfill facility; 
implement fines or bans on polluters; and initiate legislation 
giving municipalities the statutory authority to conduct 
recycling activities. 

HAZARDOUS WASTE MANAGEMENT 

While the topic of hazardous waste was not covered at length 
in the TSWMS discussion paper, many participants raised this 
topic. They were uniformly dissatisfied with the efficacy of 



controls over hazardous wastes, and suggested that "hazardous 
wastes are not dealt with in a reasonable manner. In our province 
we let a lot of people get away with a lot of things" {meeting, 
private citizen, 10/03/90) . It was suggested that "the bottlers 
of pop help you to recycle; we could go back to the sellers and 
manufacturers of hazardous waste and do the same thing" (meeting, 
private citizen, 10/03/90) . Similarly, "we must consider some 
tax or deposit on containers that will hold hazardous waste. 
Then we would be sure to get the containers back" (meeting, 
municipal sector, 09/26/90) . The return of hazardous waste to 
manufacturers was advocated by several participants: "Burlington 
spent $300,000 this year to take back old paint. It would be 
better to give this paint back to the manufacturer" (meeting, 
municipal sector, 09/26/90) . 

Provincial programs to control hazardous waste were 
generally viewed as inadequate: "I would like to see in this 
whole process more effort and thought assisting the community to 
develop hazardous waste depots. . .will there be financial supports 
for hazardous waste as well?" (meeting, private citizen, 
10/03/90) asked one participant. Another commented that "there 
appears to be a fundamental assumption made in your presentation 
and that was that all garbage is collected and hazardous waste is 
not" (meeting, municipal sector, 09/26/90) . Participants were 
concerned enough about hazardous waste to frequently bring up the 
topic of hazardous waste despite the sole emphasis on municipal 
solid waste in the TSWMS discussion paper. 



ENVIRONMENTAL ASSESSMENT 

The lengthy process related to the environmental assessment 
(EA) of landfill sites preoccupied many municipal participants. 
Many meetings with municipalities spent a great deal of time 
discussing this topic and issues related to it. Overall, 
participants complained that the Environmental Assessment Act and 
the MOE Approvals Branch created grave difficulties in planning 
and managing waste effectively in their municipalities and that 
the EA process was in need of substantial revision: "EA is an 
unworkable document, but despite being through it I can't correct 
it for you, you have a tiger by the tail" (meeting, municipal 
sector, 10/30/90) . Some participants complained that EA was 
influenced by the NIMBY factor in undesirable ways: "the big 
problem [with EA] is the lack of understanding the vast majority 
of people have with regard to waste and the fears that have been 
generated that are unfortunately of great asset to newspapers to 
scare off people on EFW and incineration" (meeting, Federal 
Government sector, -725/90) . A "level playing field" was the 
subject of concern t.'o some public sector participants. They 
suggested that "not all EA is applicable to the private sector as 
it is to the public sector... we have an obstacle in the public 
and NIMBY" (meeting, municipal sector, 09/26/90) . 



29 

MOE' s Approvals Branch was criticized for being unable to 
provide clear direction on EA-related problems. One participant 
suggested: "give some firm guidelines as well as to what the 
process is, not only for master planning but for site selection 
and that sort of thing for the EA process" (meeting, municipal 
sector, 10/11/90) . Others complained that MOE suffered from a 
lack of internal direction: "until MOE comes up with strong 
guidelines for its own staff, forget guidelines for 
municipalities" (meeting, municipal sector, 10/30/90) . 

Overall, participants tended to find the EA process to be 
time consuming, frustrating, expensive, and generally unwieldy. 
Many called for legislative changes, particularly municipal 
participants . 

METHOD USED IN THE PUBLIC CONSULTATION PROCESS 

Many participants commended MOE for conducting public 
consultation on the issue of waste management. One 
representative comment stated that the MOE should be commended 
for "the mention of putting public participation in as a 
component of your financial sustainable program. Amen to that" 
(meeting, municipal sector, 10/29/90), another that private 
industry "congratulates the Waste Management Branch for 
initiating this look at the long-term needs of the Province. . .and 
for the introduction of a process designed to encourage public 
participation" (letter, private sector, 10/23/90) . 

Skepticism was voiced as to whether public consultation 
would result in real change and whether public input would be 
acted upon by government. One participant commented that "we all 
hear about public consultation processes and there is an 
impression among people that they go nowhere" (meeting, municipal 
sector, 10/03/90) . Another stated that "we do a lot of talking 
about nothing to be doing something. . .people ignore these papers, 
it goes in the garbage and makes more waste" (meeting, private 
citizen, 10/03/90) . 

Alternatively, some participants suggested that the 
consultation process required some firm goal and direction from 
government: "I recognize a consultation has to occur with an 
initiative like this. Where do you go from here once you have 
all the comments from the respective groups?" (meeting, Federal 
Government sector, 10/25/90), and "this public consultation 
process is a political cop-out because. . .what the people need 
often is some type of direction as to what the real options are 
out there" (meeting, Federal Government sector, 10/25/90) . 

Some participants asserted that the discussion paper had 
"not reached them through normal channels" (meeting, municipal 



30 

sector, 10/30/90), and that the discussion paper did not reach 
many participants in municipal meetings. One participant 
commented that "I think that our council is aware that this came 
out, that is all I know about it" (meeting, municipal sector, 
10/29/90) . However, one participant commented that MOE "has made 
this document very accessible to the public and in welcoming 
public comment will make this process even better" (letter, 
private citizen, n.d.). 

Generally, participants indicated that they appreciated MOE 
seeking their views on waste management and that the consultation 
process was a worthwhile exercise if comments made by 
participants were considered by MOE in setting future policy on 
waste management . 

EDUCATION 

Education was consistently advocated by many sectors of the 
public as the best way to foster reduction and re-use. A large 
number of participants agreed with the representative comment 
that "the two most important Rs are reduce and re-use. I want 
more money and time spent to educate people on what the problem 
is and what we can do about it" (meeting, private citizen, 
10/01/90), and that "education is part of the solution, people 
can be taught, through the media, mailings and your newsletters 
of ways to reduce garbage output" (letter, private citizen, 
08/19/90) . A common theme was that "there are hundreds of 
thousands of citizens who would appreciate and benefit from 
information and educational programs that are accessible to 
them... we will all benefit when everyone becomes part of the 
environmental movement" (letter, private citizen, 09/12/90) . 
Specifically, one participant suggested that "educating consumers 
on environmentally sound products as well as practices should be 
considered" (letter, private citizen, n.d.). One participant 
advocated spending more money "to educate people on what the 
problem is and what we can do about it. You talk about the 
educational value of the Blue Box but that seems like a cop-out" 
(meeting, private citizen, 10/01/90) . This theme was also 
expressed frequently and seemed to be held by many participants. 

Formal education on waste management issues within the 
school system was regarded as a Provincial responsibility and 
supported by all participants expressing an opinion. Generally 
speaking, participants suggested that the Province did not have a 
comprehensive program, and needed to expand educational programs 
to further adult education through advertising and consciousness 
raising exercises: "we need more than the original 4Rs, we need 
're-educate' and 're-think' where we are going to" (meeting, 
Federal Government sector, 10/25/90), and further: "I believe 
that educating student awareness of environmental issues is 
important and necessary, but I also believe that educating the 



31 

elderly generation is another main concern" (letter, private 
citizen, n.d.). Overall, participants expressing an opinion 
favoured increased Provincial efforts to educate the public on 
the benefits of reduction and re-use. 



CONCLUSION 

The TSWMS discussion paper acted as a catalyst to discussion 
during the public consultation period. It triggered a wealth of 
written and oral comments suggesting methods to promote 
sustainable waste management practices in Ontario in the future. 
While the discussion paper raised broad themes for comment, many 
participants volunteered conceptually limited or specific 
concerns. This must be taken into account when drawing 
conclusions from this data. 

Comments received during the public consultation process for 
the TSWMS discussion paper indicated that as a whole the public 
feels very frustrated with a perceived lack of progress in 
achieving a sustainable waste management system. Many 
participants urged the Province to move quickly to confront waste 
management problems, and indicated that action on environmental 
issues was a pressing priority. Over-packaged products and the 
lack of refillable beverage containers in Ontario were dominant 
themes with private citizens. Problems in siting landfills, and 
with EFW due to environmental assessment requirements tended to 
preoccupy municipalities. 

Based on the results of the consultation, Ontarians are 
aware that sustainable development systems require a commitment 
to changing lifestyles and attitudes. They strongly support this 
concept and support policies designed to respect nature and to 
provide a healthy environment for future generations. It was 
generally felt that there is the capability and technology to 
accomplish this now. The MOE was urged to adopt strict controls 
to prevent environmentally damaging activities, and to proceed 
with specific policies and programs to achieve a sustainable 
waste management system. 



APPENDIX A. 
Glossary of Abbreviated Terms Used in the Text 



o 


3Rs 


o 


AMO 





EFW 





LCBO 


o 


MISA 


o 


MOE 


o 


MSW 


o 


NAPP 


o 


NIMBY 


o 


OMMPJI 


o 


OMMRin 



o 
o 
o 



TSWMS 

EA 
NRC 
Cof A 



- Reduce, Re-use, Recycle 

- Association of Municipalities of Ontario 

- Energy From Waste 

- Liquor Control Board of Ontario 

- Ontario Municipal and Industrial 
Strategies for Abatement Program 

- Ontario Ministry of the Environment 

- Municipal Solid Waste 

- National Packaging Protocol 

- "Not in my backyard" syndrome 

- Ontario Multi- Material Recycling 
Incorporated, (first incorporation) 

- Ontario Multi-Material Recycling 
Incorporated, (second incorporation) 

- Towards a Sustainable Waste Management 
System 

- Environmental Assessment 

- National Research Council 

- Certificate of Approval 



APPENDIX B 
DESCRIPTION OF DATA 



SECTORAL PARTICD7ATION 



SECTOR 


WRITTEN 
SUBMISSIONS 


ATTENDEES 
AT MEETINGS 


1.0 MUNICIPALITIES 

1.1 Elected Officials and the 
Municipal Public Service 


5 


124 


2.0 PRIVATE SECTOR 

2.1 Waste Management Industry 

2.2 Industrial/Commercial/ 
Institutional Waste Generators 


1 
3 



18 


3.0 GENERAL PUBLIC 

3.1 Interest Groups 

3.2 Residential Waste Generators 
(private citizens) 


3 
91 


48 
152 



4.0 FEDERAL GOVERNMENT 
4.1 Elected Officials and 

the Federal Public Service 



21 



5.0 PROVINCIAL GOVERNMENT 
5.1 Elected Officials and 

the Provincial Public Service 
Service 







APPENDIX C 
MEETINGS WITH SECTORAL GROUPS 



GROUP 

1. Rotary Club of Toronto 
(Armor Heights) 

2. Price Daxion Sales Team 
(Div. of Abitibi Price Inc.) 

3. AMO (Waste Man. Comm.) 



4. 



8. 



Northwestern Ontario 
Planning Conference 

It's Not Garbage 



Recycling Council of Ontario 
Breakfast Forum 
(no comments were recorded 
at this meeting) 

Conservation Council 
of Ontario 

Burlington City Council 
(Comm. on Sustainable Dev.) 



10. Public Fomm, Sudbury 



11. Public Forum, North Bay 



SECTOR 
Interest Group 



Commercial Waste 
Generator 

Municipal Public 
Service 

Municipal Public 
Service 

Interest Group 



Interest Group 



Municipal Public 
Service 



Public Forum, Essex- Windsor Private Citizens 



Private Citizens 



Private Citizens 



12. Region of Hamilton-Wentworth Municipal Public 

Service 

13. Region of Kitchener- Waterloo Municipal Public 

Service 



DATE/ 
LOCATION 


ATTENDEES 


09/04/90 
Toronto 


9 


09/13/90 
Toronto 


18 


09/13/90 
Toronto 


12 


09/14/90 
Fort Frances 


15 


09/18/90 
Toronto 


11 


09/22/90 
Toronto 


- 


09/26/90 
Toronto 


28 


09/26/90 
Burlington 


15 


09/27/90 
Windsor 


57 


10/01/90 
Sudbury 


70 


10/03/90 
North Bay 


25 


10/11/90 
Hamilton 


14 


10/15/90 
Waterloo 


15 



APPENDIX C CONT. 



GROUP 


SECTOR 


DATE/ 
LOCATION 


ATTENDEES 


14. Environment Canada, Energy 
Mines and Resources Canada 


Federal Public 
Service 


10/25/90 
Ottawa 


21 


15. Waste Management Master 
Plan Workshop 


Municipal Public 
Service 


10/29/90 
Toronto 


40 


16. Region of Niagara 


Municipal Public 
Service 


10/30/90 
Thorold 


13 



TONE OF ORAL COMMENTS AT MEETINGS 



TYPE OF STATEMENT 



GROUPS RESPONDING 



Request for MOE Policy 


30 


Request for Information 


16 


Request for Advice 
on Municipal Policy 


6 


Statement of Opinion 


69 


Strong Statement of Opinion 


25 


Confrontational 
Statement of Opinion 


52 


Equivocal Comment 


6 



Municipal Federal 
Gov't Gov't 



4 




5 



Private 


Interest 




Citizen 


Gtouds 


TOTAL 


12 


4 


74 


24 


23 


67 








6 


25 


4 


137 


14 


2 


49 


30 


10 


104 


1 





12 



TOTALS 



204 



96 



106 



43 



449 



APPENDIX B 

Discussion Paper Response 
Letter Log 

Tally of Comments 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Ret a Dobbs 



Rob Doherty 



ADDRESS 



Peterborough, Ont 



Peterborough, Ont 



David Buckley 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Educate on 

sound 

products; 

Reduce £ 

reuse need 

greater 

education 



Peterborough, Ont 



FINANCIAL 
SUSTAINABILITY 



Offer incentives 
to companies that 
manufacture 
reusuable products 
( minimal packaging 
Facilities should 
be publicly run — 
not private; 
opposes pay per bag 



PLANNING 



Improve Master 
Plan process - 
share info 
among munici- 
palities. 



Need to plan 
waste management 
in broader 
context of the 
environment 



TREATMENT/ 
DISPOSAL 



opposes EFW; 
limit number 
of bags for 
pickup while 
recycling 
scheme set up 



Should have 
discussed new 
technologies 
being 

considered 
(wet/dry, EFW) 



OTHER 



lack prompt 

assessment 

process, 

research for 

secure 

landfills 



William Dick 



Sue Upham 
County Lanark 
Environmental 
Action Network 
(CLEAN) 



Hazardous 
products 
manufac- 
turers be 
respon- 
sible for 
product 
recovery c 
disposal; 
change o f 
attitude 
needed 

Waste 

mgm't 

issues 

need to be 

part of 

school 

curriculum 

— Develop 

better 

markets 

for re- 

cyclables 



Supports full-cost 
accounting concept; 
producers of the 
products should pay 
their share; should 
have made economic 
connection between 
post-closure 
expenses ( problems 
— violators should 
go to jail 



Stittsville, Ont. 



Perth, Ontario 



Need more 
emphasis 
on Reduce, 
Reuse 
policies 



Northern Ontario t 
other "unorganized 
areas" need greater 
technical and 
financial help 



Agree with full 
cost accounting; 
tax Incentives for 
3R products i 
disincentives for 
disposables 



opposes EFW 



Master Plan and 
Approvals 
processes need 

clarification 



oppose EFW 



Should have 
listed other 
foreign 
systems 
examined by 
MOE (eg. 
Japan) ; paper 
should have 
listed 
examples of 
proposed 
policy and 
implications. 



Welcomes 
public 
input 
process 



Support NAPP 

initiatives 

but need to 

uncover 

hidden 

subsidies on 

virgin 

materials to 

make 

recycling 

more 

economically 

competitive 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Peter Leiss 
Chairman 
•It's Not 
Garbage" 



ADDRESS 



Toronto, Ontario 



H. Holenski 

President, 

Municipal 

Engineers 

Association 



Thorold, Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Mandatory 
Source 
separation 
— secure 
storage 
facilities 
for re- 
cyclables; 
increase 
3Rs fund- 
ing; 

industrial 
sector 
needs more 
attention. 
Manufac- 
turer 
should be 
respons- 
ible to 
reduce 
packaging; 
need 
better 
collection 
system for 
household 
hazardous 
wastes; 
More 3Rs 
education 
needed for 
students 



FINANCIAL 
SUSTAINABILITY 



PLANNING 



Need 
greater 

cooperat- 
ive 

emphasis 
on source 
reduction 
industrial 
commercial 
sector 
needs to 
be addres- 
sed; 

Need more 
education; 
Ban dispo- 
sables 
(diapers, 
cameras, 
razors) ; 
regulate 
industrial 
solid 
waste at 
source; 
make waste 
exchange 
programs 
mandatory; 
Reuse 

needs more 
policy 
emphasis) 



Provincial or 
Federal government 
needs to develop 
markets for 
recyclable i direct 
pricing schemes; 
Simplify subsidies 
( grants ( add 
incentives. 



TREATMENT/ 
DISPOSAL 



OTHER 



Create a 
Waste 

Reduction 
Office" 

Paper lacks 
political 
will for 
changes 
needed 



Approvals 
process needs 
improvement; 
Municipal role 
under EAA not 
given enough 
discussion; WMMP 
process should 
have been 
explained in 
document and 
needs 

improvement; 
Current 

regulations re: 
landfills are 
unworkable; 
Legislation for 
waste generators 
is needed rather 
than policing 
left to 
municipalities 



EFH should be 
considered an 
option 



Need better 
definition of 
environmental 
sustain- 
ability; 
Appended Spp 
of specific 
comments 
from 

municipal- 
ities 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 





COMMENTS (PRIMARY/SECONDARY) 




AUTHOR/ 
ASSOCIATION 


ADDRESS 


3Rs 


FINANCIAL 
SUSTAINABILITY 


PLANNING 


TREATMENT/ 
DISPOSAL 


OTHER 


Steve Simmans 


Peterborough, Ont 


Haste 

management 
should be 
part of 
required 
curriculum 
starting 
In early 
grades 




p. 9 Timely 
facility 
development 
important but 
EA process 
should not be 
compromised to 
hasten decisions 


oppose EFW — 
it conflicts 
with recycling 




Gerry Bernard 


Peterborough, Ont 


Recyclable 

materials 

should be 

banned 

from 

landfills 


Costs of site 
closure should be 
incorporated into 
tipping fees 


Each 

municipality 
should have its 
own Master Plan 




p. 35 List of 
facilities t 
related 
documents 
should include 
landfills so 
public has 
greater 
knowledge of 
their 
operation 


Tab Clarke 


Peterborough, Ont 


Further 

encourage 

Reduction 

c Reuse; 

Expand 

recycling 

facilities 

t develop 

greater 

markets 


Supports full cost 
accounting; Having 
producers take back 
waste is not 
efficient enough to 
ensure cost of 
disposal is 
included in prices 


Implement 
proposed 
Reg. 309 
amendments 


opposes EFW 
it conflicts 
with 3Rs 


Require waste 
audits; Goals 
on p. 21 are 
realistic c 
attainable 
without EFW 


Peter Leiss 
Chairman, 
Metro C.u.P.E. 
Council 


Mississauga, Ont. 




P rogr ams need 
expansion to 
capture industrial 
commercial wastes; 
waste management 
should be 
legislated 


Profits from 
waste disposal 
should go to 
financing 
programs that 
aren't cost 
effective 




System must 
be publicly 
owned and 

operated 


Amy Weston 


Peterborough, Ont 


Municipal 

gov'ts 

should 

pi*y 

greater 
role in 
education 
for 3Rs 
programs 
to succeed 






EFW conflicts 

with other 
3Rs goals 




A. Baldwin 


Peterborough, Ont 


Education 
currently 
directed 
to schools 
but more 
needed to 
educate 
"post- 
education" 
sector 
(ie: over 
30 crowd) 










Jackie Heath 


Peterborough, Ont 








Regulate 
distance a 
mun'plty can 
travel to dumf 
(excl.hazwste) 





DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Marsha Franklin 



Brad Deacon 



Lynn Tolland 



ADDRESS 



Peterborough, Ont 



Peterborough, Ont 



COMMENTS (PRIMARY /SECONDARY) 



3Rs 



Composting 
and re- 
cycling 
should be . 
mandatory. 
Reuse t 
repair 
centres 
should be 
included 
in talk of 
recovery 
facilities 



Peterborough, Ont 



Doris Topolsek 
Councillor 
Erin Township 



Need to 
regulate 
products 
to reduce 
waste ie: 
packaging; 
4th R: 
Recovery - 
should be 
discussed 
(Recovery 
of energy 
1 mat' Is) 



FINANCIAL 
SUSTAINABILITY 



Hazardous waste 
disposal should be 
joint effort of 
generators, govern- 
ment and public 
sector. 



PLANNING 



Hillsburgh, Ont. 



Murdo J. 
Murchiaon 



Peterborough, Ont 



Reduce 
funding to 
buy 

supplies 
to 

encourage 
better use 
of paper 



Should fund methane 
recovery process 
at landfills 



Implement tax on 
disposable products 
(cameras, lighters, 
razors, etc.) to . 
support new 
businesses that 
reduce disposables 



TREATMENT/ 
DISPOSAL 



EFW funding 
from MOE 
conflicts with 
3Rs principles 



Haz. waste 

generators 
should be 
responsible 
for collection 
/disposal of 
their products 
with gov't 
i public reps 



Funding EFW 
conflicts with 
EFH as "last 
resort" option 
— EFW should 
be considered 
last on 'list 



OTHER 



The role of 
avoiding 
purchase of 
environment- 
ally damaging 
products 
should not be 
public's role 
- need leg' In 
to control 
such products 
Document well 
written i 
easily under- 
stood, infor- 
mative. 
Recycled con- 
tent should 
be required 
as high as 
the market 
can supply, 
rather than 
simply set- 
ting a per- 
cent content 



Opposes EFW 
as it 
conflicts 
with 3Rs 



Lists 

environmental 

and 

economic 

concerns 

re: EFW 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Phyllis 

Creighton 

President, 

Conservation 

Council of 

Ontario 



Morley Fleguel 



ADDRESS 



Toronto, Ontario 



COMMENTS (PRIMARY /SECONDARY I 



3Rs 



Reduction 
targets 
timeline 
not 

ambitious 
enough — 
should be 
based on 
1988 

baseline; 
targets 
should be 
set for 
each of 
3Rs - such 
as in NAPP 



Nepean, Ontario 



R.O. Acosta 



Peterborough, Ont 



FINANCIAL 
SUSTAINABILITY 



Questions of who 
pays, t how, 
require better 
discussion. 
Paper should assess 
/address a number 
of alternate 
financing schemes 
(surcharges, 
special taxes, 
bans, etc.) 



Develop a 
4th "R": 
Refill, 
design a 
comprehen- 
sive 
refill 
system for 
all 

containers 
4 set up 
collect/ 
refill 
network 



Packaging 
needs 
enforce- 
able 
national 
standards 



PLANNING 



Waste mngm't 
policies must be 
in context of 
unified 
provincial 
environmental 
strategy; 
Incorporate this 
strategy with 
MISA, CAP. No 
rationale given 
for diversion 
targets. MOE 
should release 
policy paper by 
Mar. 31, 1991 
for public 
comment 



TREATMENT/ 
DISPOSAL 



OTHER 



Should not fund 
EFM plants 



R.G. Laughlin 

Ortech 

International 



Misslssauga, Ont. 



Necessary 

to 

increase 
R t D to 
reach 
diversion 
targets; 
R t D or: 
waste 
streams I 
how to 
"3R" them; 
create a 
centre for 
3R's R t D 



Planning needs 
all sectors and 
levels of gov't 
including 
international 



Paper fails 
to address 
associated 
air, water & 
hazardous 
waste 

programs in 
the Province; 
MISA £ CAP 
will result 
in more solid 
waste needing 
disposal. CCO 
welcomes 
opportunity 
to be full 
partner in 
future 
discussions 



Support 

"beneficiary-pay* 

principle 



Opposes EFW 
Establish 
monofills to 
take specifics 
not just all 
wastes in one 
site 



Document 
should be 
used as 
example for 
other 

provinces & 
countries; 
Laws needed 
to control 
producers of 
goods (ie: 
industry) ; 
Regulate 
advertising 
of 

disposables, 
etc. 



eg: Illinois 
EPA; 

Discussion 
paper 

excellent 



DISCUSSION PAPER 



RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Dave ErsScine 



ADDRESS 



Lindsay, Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Marianne 
Lev it sky 
City of York 
Environment 
Sub-commi ttee 



City of York, 
Ontario 



Terry Blrrel 
Manager, 
Environmental 
Affairs 
Lily cup 



Scarborough, Ont. 



Gail Be bee 
Manager, 
Environmental 
Protection 
Canadian Tire 



Build i 
fund 

Material 
Recovery 
Facilities 
— develop 
a label 
system to 
identify 
products' 
env' tal 
effects to 
educate 
public: 



FINANCIAL 
SOSTAINABILITY 



PLANNING 



Should be more 
considerate of 
landowners' 
rights re: site 
testing and 
evaluation 



TREATMENT/ 
DISPOSAL 



Opposes EFW 
as it 

de-emphasizes 
3Rs 



Support 
principle 
of front 
end 

diversion 
require- 
ment on 
recycle- 
ables 



Endorse principle 
of beneficiary-pay 
or product 
stewardship 



OTHER 



Paper very 
informative; 
enforcing 
national 
standards on 
packaging is 
a good step 



Should 
include 
4th R; 
increase 
education: 
Canadian 
Tire pre- 
pared to 
work with 
gov't; 
oppose 
■deposit 
system" 
for house- 
hold haz. 
wastes 
(fear 

liability, 
worker 
safety) ; 
Canadian 
Tire wants 
to take 
back used 
motor ail, 
but needs 
help from 
MOE 



Financing of 
recycling systems 
for secondary mat'l 
recovery should be 
cost-shared among 
all parties; 
support full-cost- 
recovery concept * 
cradle-to-grave 
concept for 
manufacturers in 
some cases 



EFW (4th R) 
should not 
have been left 
out of the 
planning 
discussion, 
supports EFW 
as one 

component of 
the system 



Support 
proposals of MOE 
surrounding 
landfills, 
Reg. 309, past 
performance for 
C. of A., «tc. 



Support EFW 



Agree with 
private 
sector 
responsibil- 
ities 
listed on 
page 10 



Ed Van Stidhout 



Peterborough, Ont 



More 

emphasis 
needed on 
Reduce 
and Reuse 



Questions the 
targets for 
diversion — 
are they really 
achieveable? 



DISCUSSION PAPER RESPONSE LETTER LOG {RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Jeanne Matthews 



ADDRESS 



Peterborough, Ont 



Ben Wolfe 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Need more 
public 
education 
on Reuse/ 
Reduction; 
Funding 
from all 
levels of 
gov't for 
reduction 
efforts; 
continue 
to fund 
R C D 



FINANCIAL 
SUSTAINABILITY 



PLANNING 



Peterborough, Ont 



Pain Oliver 



Full cost recovery: 
amount paid could 
be based on weight 
or volume of waste 
produced at end of 
manufacturing £ end 
of use by public; 
Paper looks at 
beneficiary-pay. 
Should give 
financial incentive 
to companies to use 
recycled products/ 
material rather 
than primary 
resources 



TREATMENT/ 
DISPOSAL 



OTHER 



Supports 
emphasis 
of 

at-source 
reduction; 
Manufactu- 
rers 

should pay 
for re- 
cycling 
their 
products; 
Regulate 
packaging: 
it must be 
recycle- 
able 



Peterborough, Ont 



Eric 
Bergenstein 



Supports principles 
of full-cost 
accounting; should 
require complete 
life-cycle costing 
of products; Tax 
hazardous products 



Consider bans on 

disposable 

products 



EFW financial 
assistance 
should be 
halted -- it's 
inconsistent 
with 3Rs 



Reduction 
i Reuse 
not given 
adequate 
discussion 
— Need a 
change in 
societal 
attitudes 
to reduce 
waste 



Fonthill, Ontario 



Cost of facility 
improvements, 
expansion, 
maintenance and 
closure were not 
given adequate 
discussion. How 
much will It cost 
in transition from 
today' s system to 
a sustainable one? 
Supports 
beneficiary-pay 
scheme (p. 27) Base 
tipping fees on 
composition of 
waste 



Goals set were 
reasonable and 
necessary; 
Legislate a ban 
on hazardous 
products that 
have 

environmentally 
friendly 
alternatives 



Document well 

written I 

presented 

■easily 

accessible" 

to the 

general 

reader; 

Paper lacks 

concrete 

examples of 

how to 

achieve 

goals 



Supports 

public 

consultation 

process; 

indicates a 

crucial step 

in 

co-operative 

effort to 

solve 

problems 



Packaging 
protocol not 
got enough 
priority in 
fad. ( prov. 
gov'ts. MOE 
should do an 
examination/ 
comparison of 
Sweden ( UK t 
Canadian, re: 
waste amounts 
& lifestyles 
t distribute 
it publicly 



DISCUSSION PAPER 



RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Don* Stewardaon 

Chair, 

Environment 

t Rural 

Development 

Committee 

Ont. Federation 

of Agriculture 



ADDRESS 



Toronto, Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Dan Hoornweg 
Association of 
Municipal 
Recycling 
Coordinators 



Support 
3Rs 

hierarchy; 
50* 

redcutlon- 
is too 
conserva- 
tive 



FINANCIAL 
SUSTAINABILITY 



PLANNING 



Need to 
establish 
realistic 
markets 
for recyc 
labales 
before 
implement- 
ing 

collection 
systems; 
Need more 
R i D on 
cradle-to- 
grave 
mgm't and 
impact of 
products; 
Need 
ongoing 
waste 
compositi- 
on studies 
In every 
iminc'plty 



Current HHW 
collection costs 
prohibitively high 
and do not address 
true cost of 
establishing depot. 
Full cost of life- 
cycle should be 
Incorporated into 
product cost; need 
greater funding to 
ICI sector to 
recycle 



TREATMENT/ 
DISPOSAL 



Is EFW still 
an acceptable 
option, given 
new 
government? 



OTHER 



Municipalities 
need legislated 
appropriate 
authority for 
waste flow; 
Eliminate 
private 
landfills 



Explanation 
why 

Canadians 
generate more 
waste than 
other nations 
would have 
been useful 



Al Davidson 
Haste Management 
Coordinator 
County of Kent 



Chatham, Ontario, 



Primary 
materials 
for manu- 
facturers 
are often 
more ad- 
vantageous 
than reuse 
/recycled 
materials. 
Market 
develop- 
ment 
needed 



M.W. O'Connor 

Grocery Products 

Manufacturers of 

Canada, 

Chairman 

Environment 

Committee 



Mississauga, Ont 



Current landfill 
costs artificially 
low — they don't 
account for 
remediation, 
closure. Despite 
full-cost recovery 
schemes, financial 
support will be 
needed for the 
transition; 
Financial 
suatalnability is 
multi-stakeholder 
responsibility 
requiring ongoing 
funding of capital 
t operating costs 
of municipal 
systems 



Caution 

against 

blanket 

ban on dis 

-posables; 

Support 

NAPP 

objectives 

for 

packaging 



Future plans 
were too general 
In the paper — 
how do we intend 
to reach 50% 
target; doubt 
whether new 
regulations 
will be workable 
— Streamline 
the WMMP process 
before any 
mandatory 
requirements are 
made; Priority 
should be given 
to Improving EA 
& Approvals 
process; 
Municipalities 

should be 
involved in 
formulation 



Support principle 
of financial 
suatalnability, 
increased tipping 
fees * charge by 
volume produced; 
Better system than 
tax on packaging 



Ontario too 
dependent on 
landfilling t 
not enough on 
alternatives 
to disposal; 
Facilities 
must always 
be state-of- 
the-art to 
ensure high 
env 1 r onme nt a 1 
performance; 
MOE should 
state a 
policy on EFW 
not Just pass 
it on to Min. 
of Energy. 
This policy 
should be 
proactive 



Support national 
standards and 
regulations; 
Regulations must 
be clearly 
thought out re: 
local and free 
trade 



Support EFW 
where needed 



Document 
comprehensive 
and well 
thought ot 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



R.D. Funnell 
City of Guelph 



ADDRESS 



Guelph, Ontario 



Paul Smeltzer 

Chairman 

Hamilton- 

Wentworth Haste 

Management 

Coordinating 

Committee 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Emphasis 
on Blue 
Boxes 
should be 
as an 
education 
tool, vs. 
practical 
diversion. 
Private 
sector 
should 
take resp- 
onsibility 
for their 
products; 
Return 
system for 
large good 
packaging 
is a good 
idea; MOE 
should be 
consistent 
in I of Rs 
— keep 4- 
Recovery 
isn't 
necessar- 
ily in- 
cineration 
STAR 

should go 
further; 
make 

deposits 
mandatory 



FINANCIAL 
SUSTAINABILITY 



Full cost account- 
ing" will need new 

conomic model to 
be successful; now 
economics encourage 
us to produce 
waste; Price of 
products should 
reflect cost of 
disposal; Pay-per- 
bag would need to 
be by weight, not 
volume 



PLANNING 



Long term plan- 
ning currently 
inadequate; we 
should look at 
final goal and 
work backwards, 
not just "build 
on the Blue Box" 
— Province 
should study how 
the 50% target 
will impact on 
economy; WMMP 
process needs 
improvement; 
Revisions to EPA 
shouldn't 
completely 
prohibit build- 
ing on/near old 
landfills after 
25 years 



Gov't has 

role for 

3R 

education, 

especially 

reduction. 

Develop 

markets 

for 

recycl- 

ables 



Approve of "self- 
sustaining 
principle" but with 
reservations; 
OMMRI approach 
"self-serving" - 
provides no long 
term cost relief to 
municipalities; 
Residential rate- 
payer bears 
excessive costs of 

beneficiary pays" 
system, "Green" 
taxes should be 
directed to the 
problems to which 
they were targeted 
and not into the 
general revenues 

(eg: the tire tax) 



TREATMENT/ 
DISPOSAL 



Need new 
initiatives to 
handle small 
quantity 
generation of 
hazardous 
wastes; 
Landfills are 
a waste of 
potential 
resources; 
Household haz. 
wastes should 
also include 
small 
generators 



OTHER 



Need to clarify 
auhtority for 
waste management 
through 
Municipal 
Affairs; EAA 
process needs to 
be st re ami i ned 



Title 
ambiguous; 
"Sustainable 
development" 
targets elim- 
ination of 
waste so no 
system in 
Ont. should 
be sustained 
but should be 
flexible to 
reflect the 
elimination 
of waste. The 
garbage 
crisis is a 
political not 
a technical 
problem: 
report does 
not address 
this; Packag- 
ing redesign 
should also 
require pro- 
duct redesign 
— MNR Class 
EA on timber 
dismisses re- 
cycling: All 
gov't action 
should have 
50% in mind; 
MOE as 
"protector", 
"advisor" i 
" f under" 
roles need to 
be resolved 
(they often 
conflict) 



Legislate 
action against 
illegal 
dumping; 
Clarify the 
role of EFW; 
Province needs 
to show more 
flexibility on 
options (eg: 
tire burning) 



(views ex- 
pressed by 
individual 
members) 
Document a 
good "first 
step"; 
legislate 
excessive 
packaging, 
Why was 
commercial/ 

Industrial 

sector 

left out of 
discussion 

paper? 

Minister 

should issue 

statement of 

commitment 

to goals 

established 

in the 

document 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Joan Huzar 
Consumers' 
Association of 
Canada (Ont.) 



ADDRESS 



Toronto, Ontario 



Duncan 

HacDonald 

Programs 

Coordinator 

Ontario 

Federation 

of Labour 



Don Mills, Ont. 



Price Daxion 
(Division of 
Abitibi-Price 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Good that 
3Rs 

hierarchy 
forms the 
basis of . 
the report 
'Reduction 
needs more 
emphasis; 
Gov't 
should 
resist 
pressure 
from ind- 
ustry to 
use recyc- 
liable 
cans vs. 
returnable 
bottles; 
Legislate 
recycling 
as 

mandatory; 
Need com- 
mitment to 
public 
education, 
especially 
Reuse/ 
Reduction. 
Extend/ 
educate on 
composting 
— improve 
HHW 

collection 
opportun- 
ities 



FINANCIAL 
SUSTAINABILITY 



PLANNING 



Need commitment 
from industry to 
address the 
problem that repair 
is more costly than 
replacement 



Legislate 

packaging 

supports 

suggested 

regulatory 

initiatives; 

Use full 

consultative 

process to 

design new 

regulations 



CAC 



TREATMENT/ 
DISPOSAL 



Concerned 
about EFH ash 
disposal 



OTHER 



Document' s 
philosophy 
good but 
needs action 
answers; 
Need system 
for public 
to I.D. 
products to 
avoid; 
consumers 
don't have 
alternatives 
to choose to 
avoid many 
over packaged 
products; 
Document an 
excellent 
overview of 
situation and 
gives Ontario 
direction 



What is the 
role of the 
Provincial 
Government? 

1) Involve all 
interest 
groups in 
discussion 

2) Develop 
comprehensive 
waste manage- 
ment policy, 
not in 

isolation from 
MISA, CAP, 
etc. 

3} Role as a 
model to 
others 



Comments on 
company ' ■ 
approach to 
envi ronmental 
concerns; 
(not specific 
to the actual 
discussion 
paper) 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Jill Dunkley 

Director, 

Information 

Services 

Recycling 

Council of 

Ontario 



ADDRESS 



Toronto, Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



John Paulowich 

Canadian 

Tinplate 

Recycling 

Council 



Diversion 
target of 
50% should 
be a 
minimum; 
What % 
will each 
"R" be of 
the total 
diversion? 
All pack- 
aging 
should be 
recyclable 
-compost- 
ing needs 

greater 
promotion 
and 

financial 
support; 
Blue Box 
promotion 
budget 
only $.10/ 
house/year 
( needs to 
be higher; 
Reuse 
option 
should 
extend be- 
yond soft 
drinks C 
beer 
bottles 



FINANCIAL 

SUSTAINABILITY 



RCO proposed more 
equitable cost- 
sharing formula 



Hamilton, Ontario 



PLANNING 



Unorganized 
areas "need to 
be addressed"; 
Task Force with 
MNR involvement 
needed to 
develop action 
plan to upgrade 
landfill sites 
on Crown Land 



TREATMENT/ 
DISPOSAL 



Oppose EFW 



Concerns that 
purchasers of 
recyclables from 
Blue Box program 
will be expected 
to pay higher 
prices for 
materials in 
order to cover 
operating costs 
of the 
collection 
system; To level 
the playing 
field, materials 
not being 
recycled should 
pay a penalty 
tax with money 
collected to pay 
for the Blue Box 
system — this 
will make 
industries not 
recycling, take 
on their 
responsibilities 



OTHER 



Government 
roles should 
be ahead of 
private 
sector; 
setting and 
enforcing 
national 
standards for 
packaging is 
very 

important; 
Goal 

statement is 
very encour- 
aging and 
realistic- 
Term: "post- 
consumer" 
should be 
used vs. just 
"recycled 
content" for 
recycled 
paper; should 
have list of 
definitions 
of terms in 
document; Per 
capita waste 
figures (p. 4) 
are unclear; 
Explain/ 
discuss the 
Washington 
Analysis 
Corp. table 
t figures 
(p. 7) 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 





COMMENTS (PRIMARY/SECONDARY) 




AUTHOR/ 


ADDRESS 


3Rs 


FINANCIAL 


PLANNING 


TREATMENT/ 


OTHER 


ASSOCIATION 






SUSTAINABILITY 




DISPOSAL 




Nancy 
Proteious-Koehle 


Mlssissauga, Ont . 


Price 


Consult with 


Don't support 


Facilities 


Government 




incentives 


private enterprise 


"legislation" 


should be 


must set 


n\ rector 




on virgin 


to set full cost 


approach; WMMP 


private sector 


example with 


Public Affairs 




materials 


accounting criteria 


process needs to 


— Landfill 


procurement 


WHI Watte 




should be 


— Support full 


be re-examined 


portrayed too 


policies to 


Management of 
Canada Inc. 




removed to 


cost recovery, but 


Paper falls to 


negatively; 


stimulate 




encourage 


to achieve it all 


mention the 


They are an 


markets 






use of re- 


subsidies should be 


critical role 


essential part 








cyclables; 


removed and risk 


the private 


of a sustain- 








"recycle- 


borne by supplier 


sector plays in 


able system; 








lng" means 


of the system; 


developing 


Boundaries 








more than 


Environmental 


necessary infra- 


should be 








source se- 


protection costs 


structure to 


eliminated for 








paration 


should be Included 


implement a 


transportation 








—it is 


(decommissioning/ 


waste management 


/recycling/ 








successful 


monitoring): Gov't 


system 


disposal of 








use of 


should implement 




wastes; 








collected 


financial assurance 




Larger, envir- 








materials 


mechanisms for 




onmentally 








In another 


closure, monitoring 




protective 








useful 


corrective actions 




facilities are 








product; 






better than 








Composting 
needs to 






small ones 

scattered 








be regula- 






around the 








ted; 






province; 








Responsib- 






Caution needed 








ility for 






if C. of A. 








recycling 






tied to recyc- 








should be 






ling targets; 1 






placed on 






p. 35 compost- 






generators 
— the 






ing should be 
included in 








province 
should 






list of 
facilities; 








stress 






Post closure 








market de- 






period should 








velopment 






be based on 
site monitor- 
ing, not a set 
tine frame 




P.N. Summers 


Toronto, Ontario 


Better 


Support user-pay 


Systems should 




Enclosed 


President, 




education 


principle and 


be privately run 




Canadian 


Hanson 




is key to 
achieving 
targets; 
Offer tax 
incentives 
to compan- 
ies who 
educate 
their 
staff on 
waste man- 
agement ; 
Offer 
incentives 
for doing 


economic incentives 
for 3Rs 






Manufacturers 

Association 

speech and 

sustainable 

development 

paper 






waste 


| 










audits 


1 







DISCUSSION PAPER RESPONSE LETTER LOG {RUNNING TALLY OF COMM NTS) 



AUTHOR/ 
ASSOCIATION 



D. Edgecombe 
Edgecumbe 
Consulting 
Services 



Donald Coates 
Chairman 
Ontario Waste 
Management 
Association 



ADDRESS 



Mississauga, Ont 



Etobicoke, Ont. 



(continued on 

next page) 



COMMENTS {PRIMARY/ SECONDARY) 



3Rs 



Comments 
on user- 
pay 

concept 
cites 
examples 
in Japan, 
Britain; 
should tax 
free 

newspapers 
and flyers 
that are 
distri- 
buted 
through 
street 
boxes 



FINANCIAL 
SUSTAINABILITY 



Diversion 
rate more 
than 55% - 
60% is not 
possible; 
Diversions 
must be 
encouraged 
from the 
market 
sector as 
well as 
reduction 
at source; 
Gov't 
should 
encourage 
4th "R" of 
Repairab- 
ility; 
Gov't 

should set 
example of 
3Rs thru 
its own 
practices 
I procure- 
ment 

policies; 
Public 
role 
should 
Include: 
avoid 
purchase 
of non-re- 
pairable 
items; 
Province 
should 
increase 
education 
to consum- 
ers on 
sound 
environ- 
mental 
practices; 



PLANNING 



In past, commercial 
sector of waste 
management service 
industry has been 
financially 
Independent and 
wishes to remain so 
— Federal govn't 
shouldn't have to 
fund provincial, 
municipal or 
commercial 
initiatives; Feds i 
province should 
promote national 
markets for 
materials; p. 13 
first point is not 
compatible with a 
user-pay program; 
User-pay system 
doesn't require 
government subsidy 
when true cost of 
service is recog- 
nized and charged; 
Consult private 
enterprise when 
developing full 
cost accounting 
scheme; Municipal 
haulers i private 
haulers should be 
charged same 
tipping fees. 
Cost of management 
must be borne by 
generators of waste 
— Misleading to 
say management 
costs currently 
paid out of tax 
monies. ICI wastes 
are essentially all 
managed by private 
sector on user-pay 
basis; Tipping fees 
inflated to cover 
costs of household 
waste disposal - 
true costs unknown. 



TREATMENT/ 
DISPOSAL 



Legislative and 
regulatory 
framework needs 
amendment to 
create "level 
playing field" 
for public and 
private 

operators; WMMP 
process frust- 
rating and 
unproductive; 
Approvals system 
needs workable 
framework or 
else a 
sustainable 
system is 
impossible; 
Municipalities 
should share 
responsibility 
for waste mgm' t 
with private 
sector - ie: 
partnerships; 
Review 

legislation to 
make all 
relevant Acts 
(EAA, EPA, 
Municipal Act , 
Planning Act) 



Planning Ac 
compatible 



OTHER 



Enclosed 
article on 
"Clean 
Japan 
Centre" 



Attitude 
expressed 
toward land- 
fills is too 
negative; Need 
for landfill 
must be 
recognized in 
future docu- 
ments coupled 
with environ- 
mental protec- 
tion features; 
P. 9 

Timely facil- 
ity develop- 
ment: 

MOE attitudes 
don't support 
this. MOE 
staff don't 
seem to want 
to challenge 
the status quo 
with new 
technologies ; 
Recycling and 
composting 
facilities 
should have 
site decom- 
missioning 
costs prescr- 
ibed during 
approval and 
included as 
part of uses 
fees; 
Encourage 
central 
compost 
facilities; 
Have concerns 
about minimum 
distance 
figures (P. 34) 
—P. 35 
facilities 
list should 
include com- 
post, mobile 
leachate 
treatment. 



p. 10 bullets 
1,2,5 for 
private 
sector must 
be equally 
applicable to 
municipal- 
ities to 
create a 
level playing 
field; 
Document 
should recog- 
nize that 60% 
of waste gen- 
erated is 
managed by 
private 
sector who 
should be a 
major factor 
in finding 
solutions; 
p. 16 Private 
sector not 
mentioned t . 
should be; 
Appendix I 
does not list 
past t 
current 
involvement 
of OWMA 
industry and 
"committment 
to 
excellence" 
— this is a 
serious over- 
sight of 
proven 
capability 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



(Donald Coates 
OWMA cont...) 



ADDRESS 



Thomas A. 

Derrick 

City Clerk 

City of 

St. Catharines 



St. Catharines, 
Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Gov't must 
ensure 
that 

financial/ 
regulatory 
incentives 
which 
encourage 
use of 
virgin 
materials 
over re- 
cycled are 
reversed 
to ensure 
recycl- 
ables 
markets; 
Agree that 
composting 
plays sig- 
nificant 
role and 
want to be 
included 
in public 
review of 
compost 
guidelines 



FINANCIAL 
SUSTAINABILITY 



Haste management 
can be made 
environmentally 
sustainable but not 
administratively 
nor financially 
sustainable under 
current conditions 



Need 
specific 
policies l 
financial 
support 
for Reuse/ 
Reduction 
programs; 
Develop/ 
enforce 
regula- 
tions to 
maximize 
reuse of 
beverage 
containers 
eg. 

deposit 
system; 
Extend £ 
increase 
financial 
support 
for Blue 
Box and 
other 3R 
programs, 
(discon- 
tinue 
sliding- 
scale 
method of 
funding) 



PLANNING 



TREATMENT/ 
DISPOSAL 



OTHER 



landfill gas 
management 



Paper realizes 
problems with WHMP 
t approvals but 
doesn't discuss 
solutions; 
Municipalities can 
implement 3R pro- 
grams but are con- 
strained in solving 
larger problems t 
MOE needs to 
develop workable 
solutions; Province 
placed financial 
burden on munici- 
palities to re- 
cycle without 
implementing pro- 
grams, policies and 
regulations to 1st 
reduce waste (eg. 
packaging); Concern 
with MOE tendency 
to. adopt "proposals 
t unwritten policy" 
rather than statute 
regs. with firm 
basis in law (in 
ref . to WMMP 
process) ; Need to 
immediately resolve 
approvals for mncpl 
facilities; Develop 
regs. for recycling 
i composting facil- 
ities; Involve 
municipalities in 
all formulation of 
waste mgmt policies 
/ regulations/plan- 
mi ng t strategies 



Paper doesn't 
discuss specific 
examples of 
programs or 
changes to 
regulations; 
Packaging needs 
strong commit- 
ment at both 
Federal and 
Provincial level 
to be reduced at 
source; 

Overall concepts 
in paper are 
appropriate and 
need workable 
programs to 
address problems 
in reasonable 
time frame; 
Complete the 
background 
studies 

described in the 
paper as 
necessary to 
implement 
initiatives 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 

ASSOCIATION 



j.D. McTaggard- 
Cowan 
Director 
Environmental 
Affairs 
Energy, Mine* 
i Resources 
Canada 



ADDRE5S 



Ottawa, Ontario 



COMMENTS (PRIMARY/SECONDARY) 



3Rs 



Strictly 
speaking, 

reduction 
UP 



FINANCIAL 
SUSTAINABILITY 



diversion; 

Why is 

'Recovery' 

in terms 

of incin- 
eration 

not 

included? 

What about 

Redesign, 

Rethink, 

Repair? 

Increase 

50% 

diversion 

target; 

Reduction 

needs more 

emphasis - 

recycling 

not 

diverting 

enough. 

Examine 

mass 

recycling 

rather 

than "at 

source"; 

Gov't at 

all levels 
should set 

example of 
sound 
waste 
practices; 
How were 
MOE 25 and 
SO* 

targets 
establish- 
ed? HOE 
should 
look for 
alternat- 
ives to 
current 
collection 
processing 
— Support 
4th R of 
Recovery, 
as relates 
to minor 
sector 



Who will pay for 
waste management 
system? True costs 
of Blue Box program 
(markets, etc.) 
need to be examined 



PLANNING 



Allow 

environmental 
groups to 
participate in 
decision making 
Industry' s pro- 
active role (eg 
C. A.R.I) should 
be recognized; 
Planning frame- 
work should go 
beyond the year 
2000. 

Municipalities 
lack clear 
authority/ 
mandate on waste 
management, and 
also WMMP 
process unclear. 
Site selection 
process needs 
evaluation re 
community 
Involvement. 



TREATMENT/ 
DISPOSAL 



OTHER 



Portrayal of 
waste manage- 
ment as 2- 
pronged (div- 
ersion via 3Rs 
t disposal via 
landfill/in- 
cineration) is 
too simplified 
— Should 
portray waste 
management as 
a complete set 
of options; 
Methane 

emissions from 
landfill need 
attention - 
need to divert 
from landfill 
as much as 
possible; 
Incineration 
should be 
given greater 
attention (it 
uses less land 
no groundwater 
contamination, 
no methane gas 
problems) ; 
Ontario should 
examine lesson 
learned in 
Europe etc re; 
waste mngm't; 
Needs examin- 
ation of life 
style, costs 
of products, 
suppl y / demand 
etc.; Garbage 
should be 
viewed as a 
potential re- 
source, rather 
than waste ; 
More funds for 
R t D on "how- 
tos" t use of 
economic tools 
to encourage 
industry. New 
products 
should enter 
market only 
after disposal 
recycling and 
recovery 
options have 
been consider- 
ed. Then costs 
of handling 
could be in- 
corporated 
into price. 
Product crit- 
eria developed 
prior to mar- 
ket intro. 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Mike Hyde 

Director, 

Environmental 

Affairs 

Dow Chemical 

Canada, Inc. 



Douglas Robinaon 

President, 

G.R.D.C.A. 

Governmental 

Refuse 

Collection t 

Disposal 

Association 



ADDRESS 



Sarnia, Ontario 



David Hoppner 

Chairman, 

Waste 

Resources 

Advisory 

Committee 

North Bay 



COMMENTS (PRIMARY /SECONDARY) 



3Rs 



Reduction 
should be 
discussed 
for each 
sector 
separately 
since each 
has own 
interpret- 
ation and 
industry 
has done 
much in 
the past; 
Need to 
develop 
method to 
measure 
reduction 
activities 
i their 
impacts; 
cost of 
recyclable 
products 
must 
reflect 
cost of 
virgin 
materials 
in order 
to be 
competit- 
ive 



FINANCIAL 
SUSTAINABILITY 



Industry should not 
be required to pay 
collection and 
operating costs 
now being handled 
by municipalities; 
Agree that costs 
should be reflected 
in product prices 
and borne by 
consumers; Costs 
should be reflected 
in residential tax 
bill; Costs of 
social behaviour 
should be borne by 
public and control 
of costs by 
municipality 



North Bay, Ont. 



An Integrated waste 
system should be 
allowed to process 
and divert material 
from the disposal 
option through the 
best available 
solution in the 
free marketplace; 
Tipping fees should 
be used to pay, 
plan, operate and 
close a disposal 
facility; 
Beneficiaries of 
waste diversion 
programs should pay 
for the service 



Need clear 
targets i 
time lines 
on each 
of 3Rs; 
when will 
national 
packaging 
standards 
be set? 



PLANNING 



Fully support 
full cost 
accounting, 
including tipping 
fees 



Current policy 
fails to set 
goals that are 
physically and 
financially 
sustainable; 
Proper planning 
is essential - 
proponents and 
operators of 
waste systems 
need clear 
policies and 
regulations for 
systems to be 
sustainable 



TREATMENT/ 
DISPOSAL 



Recovery of 
energy and the 
need for 
landfills 
should be 
given equal 
emphasis 



Methods and 
technologies 
to process 
waste into 
reusable/ 
recyclable 
materials 
currently 
exist, but 
infrastructure 
to support 
these does not 



OTHER 



Need a level 
playing field 
to address 
waste 

management 
issues: How 
will 

imported 
materials 
be handled? 



Haste 
management 
in Ontario 
presently 
is neither 
environmentally 
nor financially 
sustainable 



Fully support 
NAPP work 



Question 
incineration: 
due to 

environmental 
effects; 
public 
perception 
then becomes 
one of 

"produce more 
garbage to 
feed EFW", EFW 
capital costs 
too high; 
Papers lacks 
policy on 
ga rbage 
transport 



Requested 
copy of final 
report on 
input 
received; 
Fully 
support 
intentions 
put forward 
in document 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Robert Squires 
Policies 
Programs t 
Packaging Office 
of Waste 
Management 
Environment 
Canada 



ADDRESS 



Ottawa, Ontario 



A.B. Garnett 
City of Ottawa 

Department of 
Engineering 

Works 



Ottawa, Ontario 



Joan Grey 



Hark Winfield 



Nepean, Ontario 



CO' 'ENTS (PRIMARY/SECONDARY) 



3Rs 



Too much 
emphasis 
on 

di sposal 
of waste 
rat.her 
than 

Reduction 
of amounts 
generated. 
Need to 
entrench 
sustain- 
able 

develop- 
ment theme 
in 

education 
system 



FINANCIAL 
SUSTAINABILITY 



Practice full cost 
accounting to 
sustain system; 
Costs of waste 
management should 
not be taken in 
isolation, but as 
one component of 
sustainable 
development 
issue 



PLANNING 



Haste management 
requires shared 
responsibility 
at all gov'nt 
levels, 
industry and 
consumers. Gov't 
Intervention 
must consider 
industry in 
International 
context 



TREATMENT/ 
DISPOSAL 



Plan/manage 
landfills as 
limited 
resource; 
Promote 4R 
hierarchy 



OTHER 



Need to 
explain 
the 

diversion 
targets 
(what's 
the base 
year) ; 
Need 
strict 
definition 
of terms 
such as 
recycling, 
recycl ab- 
ility, etc 
— Prov. 
should go 
beyond 
Nat'l 
Packaging 
Protocol i 
take lead 
to reduce 
packaging 
waste and 
emphasize 
3R 

hierarchy; 
Province 
should 
stimulate 
markets 
and find 
studies to 
develop 
new 
markets 



Province should 
promote full-cost 
accounting and 
develop guidelines 
for use by 
municipalities in 
setting fee 
schedules; caution 
against user-pay 
system as hard to 
police and lacking 
provincial 
standard 



Too much 
emphasis on 
"end of pipe* 
solutions. 
This places 
burden on 
municipal- 
ities to 
"manage" 
wastes; 
Need change 
of attitude 
to achieve 
reduction 



Is central 
composting 
going to 
have major 
role in 
diversion 
goals? If 
how much? 



so. 



Willowdale, Ont. 



Opposes pay per bag 
- problem with 

apt's 



Paper does 

not provide 

vision of 

system 

capable of 

achieving t 

sustaining 

diversion 

goal; 

Paper lacks 

detail; 

Environmental 

sustain- 

abillty not 

adequately 

addressed 



Waste Management is 
a problem of 
economic structure 
t inefficient 
resource use; 
pay per bag is 
regressive tax. • 



Implement idea 
to look at past 
record before 
issuing new 
C of A. 
Paper should 
look beyond 
year 2000. 



Ove r-packaging 



Paper only 
offers 2 new 
initiatives; 
Government 
should do more 
re procurement 
policies to 
support market 



AUTHOR/ 
ASSOCIATION 



Audrey Voice 



John Franklin 



Mrs. Jeanette 
Arthurs 



Mr. Douglas 
Heard 



Mr. E.G. 
Etherlngton 



Ms Kathleen 
Stover 

Arthur Davis 



Hadelon West 



Sonia Sawchuk 



Wayne Haw 



Arthur Bray 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



COMMENTS {PRIMARY/SECONDARY} 



ADDRESS 
SUSTAINABILITY 



Ottawa, Ontario 



Vars, Ontario 



Ottawa, Ontario 



Cobourg, Ontario 



3Rs 



FINANCIAL 



charge per bag 

I tax credits 



opposes tax on 
garbage 



opposes pay-per-bag 
idea 



Thunder Bay, Ont. 



Forest, Ontario 



Port Lambton, 
Ontario 



Beverly Davis 



Ottawa, Ontario 



supports fee levied 
on basis of amount 
produced if 
promotes the use of 
garbage bags 
instead of cans 



suggests 
province 
wide re- 
cycling 
program. 
Including 
industries 



PLANNING 



TREATMENT/ 
DISPOSAL 



opposes surcharge 
on bags 



opposes charge per 
bag 



fee per bag would 
help encourage re- 
cycling, implement 
fee only where re- 
cycling Is in 
operation, t don't 
charge for pick up 
of materials 
recycled 



London, Ontario 



Ottawa, Ontario 



Scarborough, Ont, 



educate 

consumers 

and 

industry 

re: 

packaging 



opposes fee per bag 



Counties should 
have responsib- 
ility for admin- 
istration of 
program 



supports pay per 
bag concept 



Ottawa, Ontario 



increase 
education 
around 
reduction 



expand re- 
cycling 
programs; 
more 

education 
on waste 
reduction 



supports pay per 
bag over tax 

credit 



opposes pay per bag 



disagrees with pay 
per bag 



OTHER 



litter con- 
tainers on 
street for 
recyclables 



Ottawa City 
Council just 
rejected a 
similar 
proposal ; 
reduce excess 
packaging 



excess 
packaging 



find new dumps 
as priority 



excess 
packaging 



excess 
packaging 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COHHENTS) 



COHHENTS (PRIMARY/SECONDARY) 



AUTHOR/ 
ASSOCIATION 



Hargary V. Boyer 



ADDRESS 



letter to the 

editor; 

Thunder Bay, Ont, 



Olive Kolomy 



Alan Stewart 



Debbie Foster 



3Rs 



FINANCIAL 
SUSTAINABILITY 



Thunder Bay, Ont. 



Niagara Falls, 
Ontario 



London, Ontario 



Mrs. Marie 
Somerville 



Gail t Simon 
Linklater 



opposes pay per bag 
concept: how would 
it be policed, why 
should we pay for 
junk mail, how to 
control dumping 
into commercial 
dumpsters 



PLANNING 



opposes pay per bag 



increase 
recycling 
of plastic 
; more 
reduction 
needed 



Hamilton, Ontario 



opposes pay per bag 



TREATMENT/ 
DISPOSAL 



opposes pay per bag 



Thunder Bay, Ont. 



Mrs Verlene 
Vanderway 



Thunder Bay, Ont. 



James Somervllle Hamilton, Ontario 



Mr. P. Joannis 



Mr. Fisher 
Town Engineer 
Town of Dryden; 
Chairman of the 
Board Northwest 
Ontario Recycl- 
ing Association 



thinks tax is a bad 
idea ; 

must also hit apts 
and condo's 



opposes tax per bag 



OTHER 



This letter 
clipped and 
sent by 
other 
citizens 



opposes tax 



Gloucester, Ont. 



Dryden, Ontario 



reduce excess 
packaging 
using strict 
guidelines 



Lottery should 
go to build 
recycling 
plants 



excess 
packaging 



sent 

M. Boyer' i 

letter 



build 

incinerators 
i EFW plants 



sent 

M. Boyer' s 

letter 



opposes cost per 
bag concept 



Ralph H. 
Ret ho ret 



North York, Ont. 



repair of 

electrical 

equipment 

not 

economical 

vs. buying 

new 



excess 
packaging; 
deposits on 
soft drink 
bottles; tire 
tax not 
working 



supports EFW; 
discussion 
paper lacks 
substance in 
this area 



opposes charge per 
bag 



presents 
arguments to 
justify 
incineration 
based on 
economics, 
paper recycli 
not economics 
in the north: 
EFW is 



had seen the 
document; 
excess 
packaging 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



COMMENTS (PRIMARY/SECONDARY) 



AUTHOR/ 


ADDRESS 


3Rs 


FINANCIAL 


PLANNING 


TREATMENT/ 


OTHER 


ASSOCIATION 






SUSTAINABILITY 




DISPOSAL 




Robert Fallis 


Whitby, Ontario 




opposes cost per 
bag concept 






excess 
packaging; 

junk mail 


Mrs. V Eaton 


Brant ford, Ont. 


expand 
blue box 


opposes charge per 
bag 






excess 
packaging; 
tire tax 
questioned 


Pedro Thomas 


Ml ss i s sauga , Ont . 








build more 

recycling 

plants 




Peter Iannizzi 


j 


supports 
recycling 










Sheila Northcote 


Toronto, ONtario 


supports 


supports 




increase 


received copy 






central 


generator-pay 




household 


of Discussion 






compost 


concept 




hazardous 


paper from 






facilities 






waste days 


Dianne Poole ; 






— improve 








NAPP should 






recycling 








be enforceable 






collection 








— glass 






to avoid 














contamin- 














ation 










Margery Hedden 


Harley, Ontario 




opposes generator 
pay 








petition of 19 


Thunder Bay, Ont. 




opposes generator 




_ 


sent 


names 






pay 






M. Boyer's 

letter 


A. Cassidy 


Delta, Ontario 


government 








use less 


member of area 




should set 








paper to 


Haste Management 




an example 








print 


Plan 




of 
reduction 








documents 


Marie F. Harris 


Erin, Ontario 


supports 

hazwaste 

collection 

days i 

making 

backyard 

composters 

available; 

continue 

education 

of both 


opposes pay-per-bag 
but supports tax 
incentives for 
recycling and 
reduction 






use paper 

more 

efficiently 

in gov't 

documents; 

excess 

packaging; 

attitudinal 

change 

needed; 

manufacturers 

should be 

responsible 

for garbage 

their 

products 

create 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



COMMENTS (PRIMARY/SECONDARY) 



AUTHOR/ 
ASSOCIATION 



Mrs. J.A. 
Kennedy 



Ken Bradley 
Manager, Haste 
Reduction OWMC 



ADDRESS 



Toronto, Ontario 



Lynne Ingham 



Toronto, Ontario 



South River, Ont. 



Stormont- 
Glengarry Haste 
Management 
Master Plan, 
Public Liason 
Committee 
Patricia Gregory 



Hilliamstown, 
Ontario 



Vicky Jeffery 



3Rs 



comments 

on 

reduction; 

need to 

expand 

mat' la in 

blue box; 

legislate 

mandatory 

source 

separation 

for all 

sectors; 

legislate 

deposits 

on all 

soft drink 

containers 



FINANCIAL 
SUSTAINABILITY 



PLANNING 



more 

education 
needed; 
MOE should 
input with 
Min. of 
Education 



Strong 
lgsl'n 
needed to 
give 

direction; 
composting 
needs more 
support; 
finance 
composting 
in restau- 
rants; 
need a 
collection 
system 
province- 
wide for 
household 
hazardous 
wastes 



increase cost of 
raw materials to 
make recycling 
economically 
attractive; cost 
should lie with 
users of goods and 
services that 
produce waste 



TREATMENT/ 
DISPOSAL 



legislate a 
ban on 
incineration 



OTHER 



report lacks 

clear 
policy 

direction on 
reduction 



support full 
cost recovery 
concept 



"Unorganized 
areas- <MNR) 
need to be 
addressed 



Peterborough, 
Ontario 



Increase 
financial 
assistance 
and MOE 
staff to 
implement 
3R program 
— Budget 
should 
reflect 3R 
hierarchy 
(more S to 
reduction 
initia- 
tives) 



Manufacturers need 
to take more 
responsibility for 
costs (cradle-to- 
grave concept ) ; 
Tipping fees should 
reflect true costs ; 
suggest combining 
tipping fees and 
charge for over- 
weight garbage; 
refundable deposit 
on tires (rather 
than tax) and 
seller responsible 
for disposal 



Ontario relies 
too much on 
landfill 



opposes BPH 



Manitoba 
paper, 1969, 
"Harnessing 
Market Forces 
to Support 
the 
Environment* 



lacks 

specific ways 
to reach 
goals 
reduce 
packaging 



Increase staff 
to address 
planning; too 
much emphasis on 
landfills in the 
Master Plan 
process; need 
waste stream 
analysis 



Agree re : 
closed sites 
control 
changed from 
25 years to 
perpetuity" 



Not enough 
"how-tos" in 
the document 
- publicize 
gov't 

initiatives 
to show 
example 



opposes 
incineration 



DI 



SCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 



AUTHOR/ 
ASSOCIATION 



Frank Verge 



ADDRESS 



St. Catharines, 
Ontario 



COMMENTS (PRIMARY /SECONDARY) 



3Rs 



FINANCIAL 
SUSTAINABILITY 



extend 

recycling 

systems to 

apts, 

restaurant 

i hotels, 

malls, 

arenas; 

encourage 

home 

composting 

— recycle 

ALL food 

wastes; 

legislate 

% recycled 

content in 

packaging 



Seymour 
Applebaum 



Peter Milliken 
M.P. 



Toronto, Ontario 



PLANNING 



need to 

expand 

education 

to more 

languages 

than 

French t 

English; 

cultural 

outreach 

to get 

message to 

other 

groups 



Ottawa, Ontario 



Gordon McNulty 
Editorial writer 
Hamilton 
Spectator 



Sain Hambly 



11 names on 
petition 



TREATMENT/ 
DISPOSAL 



OTHER 



excess 

packaging 



Deposits 
on LCBO 
bottles 



Downsview, Ont. 



supports user-pay, 
pay per bag 



comments 

on 

importance 

of 

composting 



G.G. Parker 
Proctor t 
Gamble 



Toronto, Ontario 



strong 
support 
for MOE 
education 
program; 
support 
strong 
central- 
ized com- 
posting 
needs fund 



caution against 
deposit systems; 
support 

"beneficiary-pay" 
concept 



sent his 
article on 
the concept 
Cobourg 
working with 
Proctor t 
Redfern on 
user -pay 
system 



caution against 
regulation to 
achieve targets 



wrote in 
follow-up to 
MOE 
presentation 



sent 

M. Boyer's 

letter 

(Thunder Bay) 



support EFW; 
should be part 
of waste 

management 
options 



overall 
support of 
document 
with a 
number of 
specific 
suggestions/ 
concerns 



DISCUSSION PAPER RESPONSE LETTER LOG (RUNNING TALLY OF COMMENTS) 







COMMENTS 


(PRIMARY /SECONDARY 1 


AUTHOR/ 


ADDRESS 


3Rs 


FINANCIAL 


PLANNING 


TREATMENT 


OTHER 


ASSOCIATION 






SUSTAINABILITY 




DISPOSAL 




Nigel Be 11 chamber 


County of Huron 


Province 


Province should 


Province should 






Clerk - 




should 


fund municipalities 


not require 






Administrator 




play 


at 50% on ongoing 


RMMP by 










greater 


basis for re- 


municipalities; 










role in 


cycling programs 


Reform EA 










reduction 




process to 










t recycl- 




shorten time. 










ing: 




reduce cost. 










increase 














require- 














ments for 














reusable 














and 














returnable 














contain- 














ers. 














minimize 














packaging. 














provide 














markets 










Pat Crimmlns 


Regional Municip- 


Develop 




Amend EA Act to 


MOE should 




Deputy Clerk 


ality of Halton 


policies 
in support 
of all Rs, 
including 
compost- 
ing, 

inciner- 
ation of 
non-re cy- 
clables. 




speed up 
process; 

Legislate pack- 
aging require- 
ments (encourage 
reusables, limit 
disposables, 
etc.) 


prepare 
detailed plan 
for municip- 
alities on 
how to reach 
25/50% 
targets. 
Develop policy 
I legislation 
for HHW 
collection; 
consult 

municipalities 
to develop 
legislation 
placing resp- 
onsibility of 
wastes on 
producers of 
goods ( 
services 





APPENDIX C 

Newspaper Reporting 
of the 

Public Consultation Program 



EnviroScan 



Date: 0ul * 12 - 1990 



1V0 "* w,& «Wedne»a a> JtllylJ 



City. 




trash 




, By BRIGITTE AUDET 

Ottawa Sun 
, Your trash could bt worth 
blf bucks - to the"dty that 
» - if a proposal to* charge 
residents a collection fee 
par garbage bag la enacted, 
an alderman said 
yesterday. 

„Alt« Vista Aid. Derrel 
Kent tald a user-fa* would 
encourage people to recycle 
more end to stop buying 
over-packaged goods. 
He suggested a 60s fee 

Rr garbage bag last fall, 
tawa Mayor Jim Durrell 
has since announced the 
city is studying the Idea, 
which could be brought In 
this spring. 

"People will be more en- 
couraged now, especially 
when experts In Toronto are 
recommending this," he 
aald. 



iteo 



Reduce watte 

The Ontario Environment 
Ministry announced Mon- 
day tt hopes to reduce the 
amount of waste burned or 
burled by encouraging mu- 
nicipalities to charge con- 
sumers directly for garbage 

Kent* called the proposal 
"heartening." He said when 
he made a similar sugges- 
tion three years ago, the 
Idea was "blasted out of the 
ballpark." 

But he said the city has to 
provide slternatfves to 
throwing things out such at 
easy access to recycling 
and composting, before It 
can charge people for the 
amount ot garbage they dis- 
pose of. 

£ent said a recycling pro- 

Eram in apartment build- 
kga buildings would have 
to be started first 

But Ottawa Waste Man- 
agement co-ordinator Dun- 
can Bury aald a user fee 
plan would require major 
changes at the administra- 
tive level, and he's not sure 
such a plan would reduce 
the amount Of waste gen- 
erated In the city. 

Tipping fees' - the cost of 
dumping waate Into the site 
per tonne - are expected to 
rise from *« to $70 in Jan. 
MM. 



IOaQpJc Sun 

They'd charge 
you for trash 

^fLURE RICKLEY 

fee for ever h««T«ir^ pwaicoMiiiy «£, a 

bag* - 1-7 ttoeaii?? ?° ** nare l*r- 
^ «ttau faffig*i*gr -than £n e 

the ministry saysT ■ Bd "* U A. 

^StSSaSSi. tSS ^ pubUc <&»* 
*aw> ■** £ agffijg JS**" fees to 



EnviroScan 



Date: Ju1 y u » 1990 



THE OTTAWA CITIZEN ♦ TUESDAY. JULY 10. 1990 



Canada 



Ontario suggests charging 
fee per bag of garbage 

By Laura f oaertaon "~" tn r^u. * ^^ 



■y Uun Egeertson 

The Ontario Environment Min- 
istry suggested Monday that busi- 
nesses and eonaumen pay a K t 
amount for each sac of carbase 
left for collection 

The pay. 
per-big tug. 
featioo ti one 
of levcra! In a 
discussion pa 



Mo 




presented 

londay for 
•Ix monthi of 
public consul- 
tation. Gar- 
bage collec- 
tors would 
count the 

number of bap left at the curb 
- and ring up a fee for each. 

The ministry wants toi hear 
from as many memben of the 
pubUc aa poaaibie before Environ- 
ment Mtnieter Jim Bradley moves 



_Jl»y 
Consultataona 



i°.. rwover lnai consumers the 
full coat of getting rid of garbage 
He would do that through recu- 
sation*, legation or suggestions 
to municipalises. . 

' In mi, Ontario's nine million 
residents produced 10 million 
tonnea of rubbtah. In the next two 
years, 1M laodfiu piles will run 
out of apace. 

vJ^I***? Br * d,e y , » IMl of di- 
verting so per cent of garbage 
fronS being buried or Incinerated 
by the yur MOO. ceBaumen need 

with -kTJk Wbit V** P r9iw * 
with what they pay for. 

. 0th « w «y» of bringing that 
'home Include charging cooaumers 
directly through utility bills, or by 
fcvylnc K special fee If people „. 
ceed a certain weight or volume 
o/carbaje. 

Or municipalities could choose 
to reward, taxpayers with a tax 
credit if they throw out lea iar- 
bagejhaa their neighbor*. 

The direct pricing achemea are 



tossed up for discussion." miniitry 
spokesman Dennis Onn said 
"None of them have been imple- 
mented in Ontario or Canada 
Tola is a new idea." 

The town of Cobourg. about 100 
kilometre* east of Toronto, hat 
drafted a proposal to charge resi- 
dents for the number of garbage 

SBeSS ID " m in ""* WMkly 

They'd like the ministry to rec- 
ognise their community as a pilot 
project, said chief administrative 
officer Bryan Baxter. 

Jim Durrell said city auff was 
studying a fee for garbage pickup 
following AM. Dar!rel Kent's .£ 
{estlon of a 50-cent-a-bag charge 
The charge would replace the por- 
Uoa of the tax bill that now toe* 
toward garbage collection. 
"We dent think that the munici- 
lUUea are going to balk at thit.i' 




066T'9t *inr :d WQ 



uvo$oiiau% 



KAcl 



ef\W 



Ucd 



eflco R.€Cor<i ()ul>y H'.Mo 



Ontario proposes tough stance 
to curb mountains of garbage 



By Catharine Thompson 

Record staff 

TORONTO — Tough new measures to deal with the 
mounds of garbage overflowing in dumps across the 
province are being considered by the Ministry of the En- 
vironment. 

Waste controls in Ontario are inadequate, the growth 
of garbage in the province is uncontrolled and there are 
no economic incentives to change bad garbage habits, 
says a report released Monday by the environment min- 
istry, 

In a province where more than one tonne of garbage 
was produced for every person in 1987, and where some 
160 dumps have less than two years of approved capaci 
ty left, something needs to be done, the report concludes 

And it invites the public to offer suggestions by the end 
of October. 

Residents In Waterloo Region may be pleased to note 
the situation isn't as bad here as in the rest of the prov- 
ince. 

Roman Martiuk, director of Waterloo Region's solid 
waste operations, said the ministry report would make 
little difference locally He said two years ago the region 
forecast that 36 per cent of garbage would be diverted 



« We're very much a 
trend-setter within the 
province and other 
areas, fi 

Roman Martiuk 




away from landfills by 1094. through its recycling and 
awareness programs. 

"We're very much a trend setter within the province 
and other areas," he said in an interview Monday night 
"They are in fact working to catch up with us " 

Regional council is considering banning corrugated 
cardboard from Its two dumps starting in 1991, a move 
that could account for as much as )5 per cent of the 36 
per cent diversion goal. 

Some of the solutions proposed in the 40-puge discus 
sion paper include tough new regulations and increased 

See Garbage— Page A? 



Garbage 



irom Page A1 



participation by the public, industry 
and all levels of government 

The proposals are based on four 
principles: recycling, re using and r& 
ducing some of the garbage now en- 
tering dumps, tightening standurds 
for running and designing landfill 
sites, forcing garbage producers to 
pay the full costs of waste disposal, 
and speeding the approval process 
for new dumps and other waste facil- 
ities. 

The report's suggestions include- 

D dumping fees that van accord 
ing to the type of garbage brought to 
a dump, for example, charging more 
for recyciables. 

LI charging households a< i ordlng 
to the amount of their garbage 

Li expanding the blue hm recy- 
cling programs to more apartments 
and rural areas, and to im lude 
mixed plastics and cardbr.uu: 

D encouraging campaiuvs '«> do 
waste audits, to determin* ht*w cuts 
could be made in waste output 

L] improved public educuitoii pro- 
grams to encourage businesses. 



schools and homes to reduce waste. 

Last year, the ministry announced 
tough new targets to reduce garbage 
going into dumps a 25 per cent re- 
duction by 1992. and a SO per cent 
cut by the year 2000 

If those targets aren't met through 
the voluntary efforts of industries, 
municipalities and individuals, the 
report suggests the ministry in- 
crease its powers to withhold operat- 
ing permits from dumps that don't 
encourage recycling, re-use and 
waste reduction, or to require news- 
papers to contain a minimum 
amount of recycled paper. 

The report also suggests better 
standards for landfills., standards 
that take into armunl the size of the 
dump and how close it is to populat- 
ed or environmentally sensitive 
areas, and thai set out the require- 
ments for buffet /ones, leachate con- 
trol, groundwater tests, methane gas 
control and oti.fr ways of limiting 
problems thul 1 0:: f from buried gar- 
bage. 



:3&?j 






1 



v- 
-I 

i 

Go 








III! F iiif I Jaw H3 tel 

ill i ft its* iuiml ;l! 

lilt fl |«i 



i* 
*» 



i 




3 

TO 

S 

(0 



ll 



- 4 ffffi 



•Hi 
Kit!* 

Illll 

fp|P|i{ (fl ufil 

IKs #1 ! i*i i Sliff if lifl lit** If • ^*i 
-ll a r iJ s IFW Sis* Jlf lf**f l*ffg*l| 

0661*61 *l«T ;3J0Q 

__ uvosouiauj » 



i«i !«{f!ii., jw 



Date: August 31,1990 



EnviroScan 



Cash 



to put out the 



User fee^charges for garbage 
are being considered 



trash 



ere eipsorwyo, 



evteouaand 

houaenoia 



OarMMeNul- 
• I 



By GOftO MeNULTV 
USER KEES (or garbage col- 
lection art • potential new weapon 

to U^strtiggle to control waste 

Various systems Ui which 
home o w u ei s pay (or garbage Pick 
tip ecconiing to how roach thcv 
produce have boan iraptarnented 
- with some success - by various 
mumcipaiiiies m the (.' rated 
Statas. 

The 'user pav concept is now 
being studied by Hamilton- Warn • 
worth anil the Ontario environ- 
ment ministrv. which floated the 
*a in a recent dmcusnon paper 
on sustainable vaiu manage- 
ment The controversial idea » 
*l» gaining lupport among envi- 
ronroenullstt. 

A user-pay policy eouM mvotvr 
a Chirac (or each bag of gsrbag e 
collecting only bags thai hava 
stickers; special charges far home- 
owners who exceed mora (ban a 
Sven amount of garbage r rrtiu 
r people who generate lew 
want or combinations of those 



User-pay systems are touted bv 
weportan as a necessary step in 
cutting the waato « ream. U a va> 
bte price If attacked to garbage 
the theory got bouachaUi will 
hav* an incentive to reduce wast*. 
People who cut back will uvt 
money, white those who deal will 
bt penalised. 

Thare ml anv direct laceMlvt 
to cut back on household waste in 
ihe curbaide blue bos recyling prc- 
|ram. Blue bosaa curraMlv re- 
cvcle about 16 per cant oi if* 
residential watte stream as com- 
munities wnirh have Ihe service 



Evan with improvement*, blue 
bo* recyling is clearly only 'pan of 
tht answer in achieving the 
provincial foal ol diverting » per 
cant of all waste (rem landfill* or 
incinerators by 1991. am 30 par 
cant by the year moo 

Whatever the advantages, user- 
pav rvstems couM well be inure 
difficult for lbs public to accent 
thaa the innocuous Mae boxes The 
debate Inapt inainlv on canto, and 
whether user feet would be coun- 
ter-productive Opponents hjar the 
lystam would encourage more li- 
tem dumping of garbage on the 
part of mm people who wis trv to 
avoid paving 



The notion that taxpayers 
would pay twice for garbage col 

lection in a war pay approach it 
probably the greatest obstacle. In 
Ottawa, the idea wat dismissed 
out Of hand bv politicians and me 
madia because of the perception it 
would mean double taxation — a 
criticism last proponent* reject 

Supporters of uaar fees agree 
that to win public acceptance, the 
concent has to be seen at a substi- 
tute (or ihe taxes that people al- 
ready pav for garbaie collection 
and disposal — not an extra 
chare* 

A nssr-pay approach, propo- 
nmts say. would be more enurta- 
bie thaa the status quo of paying 
tor garbage collection through 
general taxation. Under the tradi- 
tional 'take away everything' ap- 
proach, people who conserve and 
put out one or two bap weekly 
pay the same as people who put 
out 10 



Recycle 

A user-pay system will ■eJUma- 
toly sink or fawn on a municipali- 
ty* success la telling the virtues of 
its efficiency The expectation that 
people who discard lens would pay 
Una Is cited as a key selling rwnt 
Intneueer-teetpproach. 

Advocates say user pay moves 
the battle to control waste further 
akasf the lib' of reduce, reuse 
and recycle. People will think 
twice about buying unnecessary or 
overpackaaBd goads. Public pres- 
tare will Maraa a t on gov er n m en t s 
at all levels to order that more 
pneatsj be recyclable and riusa. 

Hamiiton-Wemworth officials 
expect to have a report on the con- 
cept within mm months Val Ter- 
Ink. the refum's solid waste 
manager, and Phil Jensen, waste 
reduction coordinator, both say 
citiaana will need to be assured 
■ they aren't pr/tnf twice for gar- 

bage rolhni ion under anv user |wv 
plan 

A report oa user -pav mrftoni* 
in ihe IS prepared lor ihr Ham- 
tlum-liaiied Hervclinf Ailvtsorv 
Cummutee (RAO vonluden Uwl 
people are pavinf hm for nillei'. 
tion and disposal of larbaic undei 
a user-pay policy than before. 

Although residents in tome 
caaas were initially upset wnh 
paying fern strong promotional 
campaigns showing how 

householders could save munev 
overcame the opposition 

The RAC uudy atknowletlfeU 



usct-iuv iiingrams can result in a 
1mi.IiI.isIi ul illegal dumpin|. mer- 
UUf f|Rg of bags or containers, open 
burning, and other trouble* Etui a 
concluded the problans could b* 
managed with ctftctive public ed- ■ 
neat ion and some enforeemenl 

A lint step in teiling ihe idea 
the ft AC advues. begins with 
informing residents as to how 
much of their tax dollars are al- 
ready spent on garbage collection 
and disposal 

Unless tins hitherto invisible 
cost is itemiasd on each taxpayers 
bill, it will b» difficult to show how 
people can aave with a user-nay 
system. 

Waste nunagemeht'i'osts " for 
municipulitiel thai have the data 
■ml lined in Ihe KAC study incluue 
11 US per household jnnually in 
MuNtsauga. ttatf) in Metro To- 
ronto, and M7 IS in Ottawa. 

The RAC study estimates Ihe 
con of collection, per bag. works 
out in IT cents in Toronto and 13 
ccNs in Ottawa. Out it noits thai 
bags would likely cost more in any 
user-pay system, 

Thai's because the figures cov- 
er operating i sp ea ais only They 
don't include the full capital costs 
of MH«' programs, waste manage- 
ment j no environmental planning. 

landTill tile aequoiuons and clos- 
incs. and the Ilka. 



The RAC report stresses that if 
people are to be asked to buy spe- 
cial garbage bags, they have to be 
tiwd what it now costs them in 
taxes to collect each and everv 
bag Those taxes would be re- 
placed with the new system. 

Pouttciam will have to make 
sure industries llkewme pav user 
fees that reflect the full coat of 
handling waste Although mumci 
ualiuea generally charge tipping 
fees at landfills and other facilities 
based on weight or volume, the 
environment ministry tavs those 
fees vary widely — from non-exn- 
Unt to almost 1 1 00 per tonne. 

The ministry wants municipal- 
Hies to determine toe full costs of 
waste management and disposal. 
then set realistic tipping fees that 
will cover those coats. In the pro- 
cess the expense would be shifted 
from property taxes. 

The RAC study found that wjc- 
caeslul user-pay systems not only 
help taxpayers, they can help mu- 
nicipalities save money too — es- 
pecially where a fioanrtallv self. 
supporting wast* management 
agency or utility has been estab- 
lished to operate the service 

Seattle. Washington has a self. 
supporting uner-pey svstam based 
on charging nouseboider* for the 
number of garbage cans they set 
out Managed by the Seattle solid 
Waste Utility, ihe ivstetn charges 
ho m ah n ldert 113 TJ j month ir* i 



EnviroScan 



Date: July 19,1990 



Page: 



T HE OSHAWA TIMES, Sattrtsy, July 14. 1990 



i3diton Geriy Rose - 723-3474 



Province seeking 
input over waste 
management plan 



Ry Christy Chue 
oummiiMimif 

Lew garbage, higher costs for 
disposing of it and tougher landfill 
standards are among the options 
being put forward by the province 
in a discussion paper. 

Towards A ._ 

Sustainable 
Waste Manage- 
ment System, 
Just released 
by the environ- 
ment ministry, 




the province 
can promote in- 
novative, aw- ■* 
taioabte wast* BRADLEY 
management practices in Onta- 
rio. The province la looking for 
comment* from the public on the 
paper and the ideas within it. 

One oT the major options 
strom the need to reduce reli- 
ance on waste disposal and intead 
concentrating on the 3 Rs - re- 
duction, re-use and recycling. Ex- 
pansion such practices would 
main a significant drop in gar- 
bage to be disposed of and save 
new resources, the paper states 

Another concept u that of "full 
cost recovery" which would re- 
quire waste producers to pay full 
costs of waste management and 
disposal, this would provide the 
necessary funds to set up, oper- 
ate, close down and replace facili- 
ties which providing incentive for 



waste reduction, the paper says. ' 

New regulations regarding 
waste management facilities, 
such as dumps, are proposed to 
further protect the environment. 

Educational programs to in- 
form Industry, consumers and 
atudents about waste reductions 
are also suggested 

"The ideas contained in ibis pa- 
per will help us acbeive our goals 
of diverting 33 per cent of all 
wastes into productive uses and 
away from landfill and incinera- 
tion by 1903 nod SO per cent by the 
S»f .WW/' Mid Environment 
mister Jim Bradley. 

Meanwhile the ministry an- 
nounced It Is approved funding for 
mora than li«,6oo home compos- 
ten throughout the province to 
help reduce waste. Nearly S3 mil- 
Hon has been spent In the last year 
to help 44 communities provide 
home composters to residents. 

Kitchen and yard wastes, which 
can go into the composters, make 
up one-third, of household waste 
going to dumps. 

The ministry is looking for peo- 
ple's comments on the waste 
management paper and will send 
out members of the waste man- 
agement branch to make group 
presentations on the paper, eopiel 
of which may be obtained by ai- 
ling the public information centre 
at 41*423-4331 In Toronto. 

Group presentation can be ar- 
ranged from July to Oct. 31 by 
caJluiMM) 333-5200. 



Region decides to, 
continue composting 



A central composting facility 
ibaveiw 



fflESS, 11 1W1 »«• *• establishment of a cc 
wg uatspn committee to ensure public input into the oroiect 

and X?w^ E" ing <■««>•*" * ™paopii /wffiRe I 
iSE^SrSZJMf n no 1 w *?»o compost their own material, m R el i 

fm«Ut would be expanded across Durham with more EXeT buUt a 



tat** mZ^J^TZZr Tfle «rm also talked with Uire* mawr or 
HSU cSegT Durh * m ~ Craer * 1 Uol9n ' *** m r'armTal 

by S fflSn a,M * CUrteWe "**»* * fwd *"<«• W rccommcMdoi 



A8 Tuesday, July 10, 1990 THE TORONTO STAR* 

Composting 
catching on, 
province says 

By David braelson 

TORONTO STAR 

More and more people in Ontario are going 
to catch on to recycling their kitchen ana yard 
waste into home composting bins, Ontario's 
environment minister says. 

Jim Bradley said yesterday the province has 
given already $3 million to municipalities for 
Backyard composters — plastic bins that turn 
table scraps into fertilizer for the garden. 

Now the program will likely expand because 
the government hopes to reduce the amount of 
garbage in Ontario by 25 per cent within two 
years and a further 25 per cent by the end of 
the decade. 

. "Composting is an important tool to help us 
meet our goal, Bradley said in a statement. It 
can "reduce the volume of garbage now sent 
to landfill sites or incineration." 

To compost, householders put yard dip* 
pings and leftover food (except meat) into the 
plastic bins, where it "cooks" over several 
weeks into nutrient-rich material that can be 
spread over the garden. 

- The provincial money will help 44 munici- 
palities offer cut-rate prices for the bins. They 
retail for as much as $125 but have been sold 
by Metro for less than $20. 

The province's program has already pro- 
vided more than 116,000 home composters 
across Ontario. 

Metro and other southern Ontario munici- 
palities are running out of landfill space and 
incineration is opposed by many environmen- 
talists, who believe the fumes are a health haz- 
ard. 

' The minister's statement yesterday came as 
he released a new discussion paper on waste 
reduction that says the amount of Ontario's 
garbage could be decreased by charging peo- 
ple more to get rid of it. 

. The new report says Ontario should consid- 
er: 

O Full recovery of the cost of disposing gar- 
bage — a cost hidden in a maze of subsidies 
and grants from one level of government to 
another. 

□ More reliance on reducing the amount of 
waste so that less disposal wulbe needed. 



Globe <wl /foil 9 u 'y "»^° 



NATIONAL NEWS 



Pollution Probe rejects ministry's proposal 

Strategy paper on waste collection should be recycled, critics say 



BY RICHARD MACKIE 
'Queen'! Firk Bureau 

TORONTO — Pollution Probe is 
calling the Ontario Environment 
Ministry's proposal to reduce gar- 
bage by charging for waste col- 
lected at households and by charg- 
ing more Tor garbage going to land- 
nil sites "pathetic". 

Ministry officials have also pro- 
posed that companies producing 
potentially dangerous wastes be re- 
quired to collect them after they 
have been used by consumers. 

The new strategy on waste man- 
agement would ensure that "waste 



generators and beneficiaries of 
waste management services pay the 
'full cost' of these services." 

But Pollution Probe spokesman 
Dave McRobert said Ontario's dis- 
cussion paper should have been re- 
cycled before it was distributed. 
"This discussion paper epitomizes 
the pathetic inaction of this provin- 
cial government on our waste crisis. 
. . . The only thing this paper 
will sustain is our massive levels of 
garbage production. " 

At present, the prices charged for 
getting rid of garbage generally are 
far below the true costs of dispos- 
ing of it, said Hardy Wong, director 



of the ministry's waste management 
branch. 

For example, many municipali- 
ties in Ontario underestimate the 
cost of operating, closing-out and 
maintaining landfills and other 
waste management and disposal fa- 
cilities, the strategy paper says. 

The strategy paper proposes tip- 
ping fee schedules for private haul- 
ers that would vary according to 
the type of waste brought to a mu- 
nicipal dump, including higher 
charges for recyclable material. 

Among the options the paper 
suggests are: 
• Charging for each bag collected. 



• Collecting only bags that are pur- 
chased from a municipal waste 
management authority. 

• Charging householders directly 
through utility bills. 

• Charging a special fee if a house- 
hold discards more than a given 
amount of solid waste per month or 
annual quarter. 

• Providing a tax credit if the waste 
generated is less than a given 
amount. 

Mr. Wong stressed that the min- 
istry hopes that consumers, faced 
with these higher costs, will serious- 
ly consider how best to limit 
creation of waste. 



TUESDAY, July JO, 1990 



The London Free Press 



Garbage 



Homeowners could face 
charges for each bag 



It's just one of the proposals the environment ministry is 
presenting for six months of public discussion. 



By Laura Eggertaon 

Canadian Press 

What do garbage bags and dollar bills 
have in common? 

They're both green — and Ontario's 
environment ministry wants 
consumers to start connect- 
ing them. 

in a discussion paper re- 
leased Monday, the ministry 
proposes that businesses, in- 
dustries, institutions and con- 
sumers should start paying 
the full cost of getting rid of 
garbage. 

Get ready for garbage col- 
lectors to count the number 
of bags you're dropping at the 
curb — and ring up a fee for each. 

That's just one of the proposals the 
ministry has drafted and presented for 
six months of public discussion. 

By October, the ministry wants to 
have heard from as many members of 
the public as possible so Environment 
Minister Jim Bradley can take action on 
his proposals — either through regula- 
tions, legislation or suggestions to 
municipalities. 

In 1987, Ontario's nine million resi- 




^ #wwwtMao ^to«**M*»^^»w^*»»M«c■ 



dents produced 10 million tonnes (11 
million tons) of rubbish. In the next two 
years, 160 landfill sites will run out of 
space to hold it all. 

"We all have to be serious about 
waste management," ministry spokes- 
man Dennis Onn said. 
"We're all stakeholders in the 
future of die system." 

To reach Bradley's goal of 
diverting 50 per cent of gar- 
bage from being buried or in- 
cinerated by the year 2000, 
consumers need to connect 
what they produce with what 
they pay for, the ministry 
says. 

Other ways of bringing that 
home include charging con- 
sumers directly through utility bills, or 
by levying a special fee if people exceed 
a preset weight or volume of garbage. 
Or municipalities could choose to re- 
ward taxpayers with a tax credit if they 
throw out less garbage than their 
neighbors. 

"The direct pricing schemes are 
tossed up for discussion," Onn said. 
"None of them have been implemented 
in Ontario or Canada. This is a new 
idea." 



Cobourg, population 13,000, is at the 
forefront of the trend. 

The tree-lined town about 100 kilo- 
metres east of Toronto has drafted a 
proposal to charge residents for the 
number of garbage bags they toss out in 
their weekly collection. 

PHOT PROJECT: They'd like the minis- 
try to recognize their community as a 
pilot project, said chief administrative 
officer Bryan Baxter. 

hi part, the town is motivated by a 
rapidly filling landfill she, scheduled to 
dose in August Industries and busi- 
nesses are already forced to truck their 
waste to nearby Napanee, where they 
pay $100 per tonne to dispose of it. 

Cutting household waste by limiting 
the number of bags one can place curb- 
side is the next possibility. 

"One of our options is to charge a fee 
for all bags or containers," Baxter said 
in a telephone interview. 

The town wants to "get the message 
across to the users of the service to 
reduce the quantity (of garbage) and to 
preserve and extend the life of our land- 
fill site," Baxter said. 

The ministry wants more municipal- 
ities to look at Napanee's option of 
charging per tonne of garbage they ac- 
cept from industries. 

"We don't think that the municipal- 
ities are going to balk at this," Onn said. 



APPENDIX D 

July 9,1990 News Release: 

"Expanded 3Rs, 

Full Cost Accounting 

Tougher Standards Seen 

As Keys to Sustainable 

Waste Management" 




news release 



Ontario 



Ministry 
of the 
Environment 



July 9, 1990 

FOR FURTHER INFORMATION: 

Dennis Onn, (416) 323-5092 
Waste Management Branch 

Jonathan Greenbaum, (416)323-4613 
Communications Branch 



EXPANDED 3RS, FULL-COST ACCOUNTING, TOUGHER STANDARDS 
SEEN AS KEYS TO SUSTAINABLE WASTE MANAGEMENT 



Expanded 3Rs (reduction, reuse and recycling) efforts, 
tagging waste generators with the full cost of waste management, 
and tougher landfill standards, are among the options being put 
forward in a report released today by the Ontario Ministry of the 
Environment . 

Some of the central proposals contained in the paper 
entitled Towards A Sustainable Waste Management System include: 

- The need to reduce our reliance on waste disposal 
through the promotion of the 3Rs (reduce, reuse and 
recycle) . The expansion of such practices would bring 
about a significant drop in the amount of waste requiring 
disposal, the paper says. This would cut unnecessary 
consumption of new resources. 



. . .NR#286/90 1/3 



- The principle of "full cost recovery", by which waste 
producers would be obliged to pay for the full costs of 
waste management and disposal. A waste management system 
based on this principle would provide the revenues needed 
to establish, operate, close out and replace facilities, 
while providing incentive for waste reduction. 

- Improved waste management facility standards to further 
protect the environment. New regulations are proposed to 
upgrade the design and operation of waste management 

facilities. 

- Programs to inform industry, consumers and students about 
how to make decisions that contribute to a reduction of 
the waste generated in the province. 

"The ideas contained in this paper will help us achieve our 
goal of diverting 25 per cent of all wastes into productive uses 
and away from landfill and incineration by 1992, and 50 per cent 
by the year 2000," Mr. Bradley said. 

The discussion paper provides an overview of current 
ministry programs in the waste management field and discusses how 
the province can promote innovative, sustainable waste management 
practices in Ontario. 



. . .NR#286/90 2/3 



The ministry is seeking comments from the public on the 
ideas in the paper, and will use this to determine future waste 
management policy. Members of the ministry's Waste Management 
Branch will make group presentations, note comments and answer 
questions about the discussion paper. Group presentations may be 
arranged from July to October 31, 1990, by calling the Waste 
Management Branch in Toronto at (416) 323-5200. 

Copies of the paper may be obtained by calling the Public 
Information Centre at (416) 323-4321 in Toronto. 



- 30 - 



Version francaise disponible . . .NR#286/90 3/3 



APPENDIX E 

Schedule of 

Public Presentations 

by Waste Management 

Branch Staff 



SCHEDULE OF PUBLIC PRESENTATIONS 

BY 

WASTE MANAGEMENT BRANCH STAFF 

PUBLIC CONSULTATION ON THE FUTURE OF WASTE MANAGEMENT 

IN ONTARIO 
"TOWARDS A SUSTAINABLE WASTE MANAGEMENT SYSTEM" 



DATE/TIME 
Aug. 23 § 11:00 a.m. 

Sept. 4 e 7:30 a.m. 
Sept. 13 @ 9:00 a.m. 

Sept. 13 6 12:00 noon 

Sept. 14 8 10:45 a.m. 
Sept. 18 8 7:00 p.m. 

Sept. 21 @ 9:30 a.m. 
Sept. 2 4 @ 8:00 a.m. 

Sept. 26 @ 11:00 a.m. 
Sept. 26 S 12:00 noon 

Sept. 26 § 7:00 p.m. 



LOCATION 
Erindale College 



Ramada Inn 

185 Yorkland Blvd., 

Toronto 

Avis International 

Hotel 

6090 Dixie Road 



AMO Office 

100 University Ave, 

Toronto 

Red Dog Inn 
Fort Frances 

Toronto City Hall 
Committe Room 2 



439 University Avenue 
11th Floor, Toronto 

Royal York Hotel 
Ballroom, Toronto 



Ontario Hydro Building 
700 University Avenue, 
Toronto 

Waterloo Motor Inn 
Waterloo 



City Hall, 426 Brant 
Street, Burl ingt on 



AUDIENCE 

national seminar of 
teacher' s association 
(KEY) Knowledge of 
Environment for Youth 

Rotary Club of 
Toronto-Armour Heights 



Price Daxion, Div. of 

Abitibi Price Inc. 

- sales and management 

team 

AMO Waste Management 
Committee 



Northwestern Ontario 
Planning Conference 

"It's Not Garbage", 
Coalition of 
community, labour, 
business and 
environmental groups 

Metro Works Department 



Recycling Council of 
Ontario, Breakfact 
Forum - "Sharing the 
Costs of Waste 
Management" 

Conservation Council 
of Ontario 



Industrial Accident 
Prevention 
Association, Grand 
Valley Division 

Burlington' s 
Sustainable 
Development Committee 



- 2 



"TOWARDS A SUSTAINABLE WASTE MANAGEMENT SYSTEM" (CONT'D) 



DATE/TIME 
Sept. 27 @ 7:00 p.m. 

Oct. 1 @ 10:30 a.m. 
Oct. 1 @ 9:30 p.m. 



Oct. 3 @ 7:30 p.. i . 

Oct. 5 @ 12:00 noon 

Oct. 10 @ 11:00 a.m. 
Oct. 11 @ 9:00 a.m. 

Oct. 11 8 1:30 p.m. 
Oct. 15 @ 11:00 a.m. 

Oct. 18 @ 11:00 a.m. 



LOCATION 



Ciociaro Club 
Windsor 



40 St. Clair Ave. W. 
Toronto 



Public Library 
Sudbury 



Council Chambers 
North Bay 



2700 Matheson Blvd. 
East Tower, 8th Floor 
Missis sauga 

160 Bloor Street East 



Canadian Football 
Hall of Fame 
Main Auditorium 
58 Jackson St. West 
Hamilton 

Dow Chemical 
Etobicoke 

Marsland Centre 
Waterloo 



McCarthy-Tetrault 
Toronto Dominion Bank 
Tower, 47th Floor, 
Toronto 



AUDIENCE 



Open public forum 
promoted by the Public 
Advisory Comm., Essex- 
Windsor Waste 
Management Committee 

Premier's Council on 
Health Strategy, 
Healthy Ecosystems 
Sub-committee 

Open public forum 
(panel discussion) by 
the Sudbury Round 
Table on Health, 
Economy and the 
Environment 

Open public forum 
promoted by the Waste 
Resources Advisory 
Committee, North Bay 
Town Council 

WMI Waste Management 
of Canada 



staff from Unilever 
Inc. /Thomas J. Lipton 

Region of Hamilton- 
Wentworth, Waste 
Management 
Coordinating Committee 



executive staff of Dow 
Chemical 

Environmental 
Engineering staff of 
the Regional 
Municipality of 
Waterloo 

Executive groups of 
Ontario Waste 
Management Association 
(OWMA) and the 
Government Refuse 
Disposal and 
Collection Association 
(GRDCA) 



3 - 



"TOWARDS A SUSTAINABLE WASTE MANAGEMENT SYSTEM" (CONT'D) 



DATE/TIME 



LOCATION 



AUDIENCE 



Oct. 23 @ 10:00 a.m. 



Oct. 24 @ 12:00 p.m. 



Oct. 25 e 9:00 a.m. 

Oct. 29 @ 10:00 a.m. 

Oct. 29 @ 1:00 p.m. 

Oct. 30 @ 9:30 a.m. 

Oct. 31 @ 2:00 p.m. 

Nov. 1 6 7:00 p.m. 



Nov. 6 @ 1:00 p.m. 



Nov. 14 @ 11:00 a.m. 



Ontario Research 
Foundation, Sheridan 
Park Research 
Community, Missis sauga 

University of Toronto 
1265 Military Trail 
Scarborough 



588 Booth Street 
Department of Energy, 
Mines and Resources 
Ottawa 

15 Gervais Drive, 
Toronto 



Airport Venture Inn 
Toronto 



Municipal office, 
Thorold 



OMMRI office, Toronto 



Lakehead University 
Thunder Bay 



20 Wildwood Road 
Georgetown 



Skyline Hotel 
Toronto 



Staff of the Ontario 
Waste Exchange 



Students taking part 
in the University's 
Environment Awareness 
Week (cancelled 
because no students 
attended) 

staff from the 
Departments of Energy, 
Mines and Resources 

and Environment 

Ontario Federation of 
Labour (OFL) and 
Canadian Union of 
Public Employee' s 
(CUPE) 

municipal officials 
attending a Waste 
Management Master 
Planning (WMMP) 
Workshop 

public works officials 
from the Niagara 
Region 

staff of OMMRI - 
Ontario Multi-Material 
Recycling Inc. 

open public forum for 
citizens of the 
Thunder Bay area and 
the Lakeland 
University "Echo" 
association - 
Environmental Choice 

executive members of 
the Association of 
Municipal Recycling 
Coordinators 

Canadian Manufacturers 
Association 



1 



-r- 

I""; 

aoo 
BO 

:C 

|o 
15 

-O 

IS 
K5 

= CD 

Ico 




SEMINAR ON: 

IMPACT OF NEW AND PROPOSED 

EFFLUENT REGULATIONS 

ON MUNICIPAL AND INDUSTRIAL 

WASTEWATER TREATMENT 



NOVEMBER 9, 1988 



PROCEEDINGS 



ORGANIZED BY: 



POLLUTION CONTROL ASSOCIATION 
OF ONTARIO 



TD 
430 
.147 
1988 

MOE 



ONTARIO MINISTRY OF THE ENVIRONMENT 



ffb^ 



l-f 



2 1 -ni- 1yy/ 



%q kW 



IMPACT OF NEW AND PROPOSED EFFLUENT ) 

REGULATIONS ON MUNICIPAL AND INDUSTRIAL 
WASTEWATER TREATMENT 



Proceedings of a seminar held 
at the 
Waterloo Inn, Waterloo, Ontario 



NOVEMBER 9, 198 8 



sponsored and organized by: 
POLLUTION CONTROL ASSOCIATION OF ONTARIO 

and the 
ONTARIO MINISTRY OF THE ENVIRONMENT 



Seminar Co-Chairmen: Ralph Luhowy, 

Region of Waterloo 

Steve McMinn, 

M.M. Dillon Limited 



TABLE OF CONTENTS Page 



MINISTRY OF THE ENVIRONMENT POLICY UPDATE 1 

Nars Borodczak, 

Ontario Ministry of the Environment 
(ABSTRACT ONLY) 

THE SOUTHWESTERN REGIONAL APPROACH: HOW TO DETERMINE 
CERTIFICATE OF APPROVAL NUMBERS 3 

Doug Huber, 

Ontario Ministry of the Environment 

METAL FINISHING INDUSTRY POSITION 9 

Kenneth Coulter, 
Canadian Association of Metal Finishers 

POLLUTION CONTROL PLANNING AND BASIN MANAGEMENT 

IN THE REGION OF WATERLOO 19 

George Zukovs, 

Canviro Consultants 

IMPACT ON DESIGN AND OPERATION OF MUNICIPAL 

TREATMENT PLANTS 31 

Bob Pickett, 

Metro Toronto Works Department 

THE US EPA TOXIC REDUCTIONS PROGRAM 43 

Henryk Melcer, 
Environment Canada 
(ABSTRACT ONLY) 

IMPACT ON MUNICIPALITIES 45 

Clare Bauman, 
Regional Municipality of Waterloo 

PANEL DISCUSSION 57 



- 1 - 



ABSTRACT ONLY 



MINISTRY OF THE ENVIRONMENT 
POLICY UPDATE 

by: Nars Borodczak, 

Ontario Ministry of the 
Environment 



An update was presented of Ontario Ministry of the Environment 
policy on industrial and municipal wastewater regulations, 
with emphasis on the Municipal Industrial Strategy for Abatement 
(MISA) program. The schedule for industrial monitoring regul- 
ations and the expected timing for the municipal sector were 
outlined. 



- 3 - 



THE SOUTHWESTERN REGIONAL APPROACH 
HOW TO DETERMINE CERTIFICATE OF APPROVAL NUMBERS 
By: D. Huber j 

Each Region of the Ministry of the Environment has a 
slightly different approach to determine criteria or numbers 
for Certificates of Approval. Presently, there is an effort 
under way by the Water Resources Branch in Toronto to try 
and standardize the approaches and requirements. This paper 
deals with the approach developed by the Southwestern 
Region. It is an evolutionary approach, which is still 
evolving, and is not a cookbook approach which says you must 
do this then that. It outlines a series of steps that the 
consultant can go through, with various options, to produce 
a report that will be acceptable to determine Certificate of 
Approval criteria by the Region. 

This Region like the others has been accused of using 
many methods to determine Certificate of Approval criteria, 
e.g. throwing darts, rolling dice or just picking the 
numbers out of the air. This Ministry's new program MISA 
BAT-EA (Best Available Technology - Economically Achievable) 
will raise the minimum standard of treatment required for 
all major pollution contributing sectors. For the municipal 
sector, this was the requirement for at least primary 
treatment (settling for solids removal) and now MISA may 
raise the minimum treatment level to secondary treatment 
{settling plus biological oxidation) . Wherever MISA takes 
us, the Certificates of Approval criteria may have to be 
more restrictive based on receiving stream impact studies. 
The surface water quality goal of this Ministry, as laid out 
in the "Blue Book" (Water Management Goals, Objectives and 
Implementation Procedures of the Ministry of the Environment 
Revised May 1984) , is to ensure that the surface waters of 
the Province are of a quality that is satisfactory for 
aquatic life and recreation. This stresses the need to know 
as much as you can about the waste receiver. 

To develop Certificate of Approval (C of A) criteria, 
one requires information on : local water quality conditions 
(e.g. the bacteriological, chemical, physical and 
biological), streamf low/currents, existing water uses along 
with existing or proposed raw waste strengths and waste 
flows. The more real data one has available, the easier it 
is for the consultant to do the job. 



Douglas M. Huber, Regional Hydrologist and Assoc. 
Surface Water Evaluator, Southwestern Region, Ontario 
Ministry of the Environment 



- 4 - 



The consultant should contact the Technical Support 
Group in the respective Region to obtain information on the 
stream-based water quality criteria. These values may be 
different for different rivers. For example; turbid rivers 
can handle more phosphorus than clear-flowing rivers and 
warm-water fishery streams require less dissolved oxygen 
than cold-water fishery streams. After you have informed 
them about your type of discharge and approximate volume, 
they may provide stream based water quality criteria that 
may include: 

un-ionized ammonia dissolved oxygen 

total phosphorus suspended solids 

B0D5 total chlorine residual 

hydrogen sulphide various metals 

E. coli/fecal coliform phenols 

These values will be used by the consultant to protect the 
aquatic life present in the receiver. Also any variation in 
criteria, summer to winter etc. should be provided at this 
time. The information from Technical Support must be up to 
date. An eight-year old memo on water quality is just not 
acceptable. If the project has been shelved or you have not 
dealt with Technical Support for over eighteen months about 
this project then get the information confirmed. There may 
be new water quality parameters of concern or changes in 
downstream water uses etc. Additional concerns or 
restrictions about the discharge should also be identified 
at this time. There may be seasonal restrictions because of 
low streamflows or fish spawning. The discharge must not be 
toxic and this point results in maximum concentrations for 
un-ionized ammonia, total chlorine residual and heavy metals 
just to name a few parameters. If the discharge goes to a 
lake, then information on minimum distance out from shore 
and water depth should also be provided. Be realistic about 
the time it takes to amass this information. Just don't 
walk into a Ministry Office and expect to leave with the 
required information in a matter of minutes or even hours. 

The next step or while your waiting for data or the 
requested information to be forwarded , get familiar with 
the existing streamflow data for your discharge location. 
You may be lucky and have a continuous recording stream 
gauge at your location but the odds are against it. 
Determine if pro-rating is acceptable or if you can develop 
a correlation between daily spot measurements and daily 
flows at the continuous gauge. A new report dealing with 
techniques on how to estimate streamflow for ungauged 
streams from gauged streams will be available from the Water 
Resources Branch in Toronto during spring of 1989. This 
report may be of assistance or you may wish to use some 
other approach. Just explain the approach you want to use 
and get approval for it now. Also get your approach to 



- 5 - 



ranking and recurrence interval calculations confirmed be it 
Gumbel, Log Person etc. 

Now that you are familiar with the streamflow data, 
which flows are you going to use? For a continuous year 
round discharge, we normally require the 7Q20 (minimum 
average seven-day streamflow with a 20 year reoccurrence 
interval) streamflow to be used. For seasonal discharges 
depending on stream sensitivity, we recommend either a 
minimum 1 in 10 monthly average or minimum 1 in 20 monthly 
average. Monthly 7Q10 (minimum average seven-day streamflow 
with a 10 year reoccurrence for that specific month) may be 
required for a continuous winter discharge with a drop of 
storage in the spring. Depending on the exact scenario, we 
have used minimum weekly flows with 10-year reoccurrence, 
worst year on record and NO DIRECT DISCHARGE at all. This 
may force the applicant into infiltration or spray 
irrigation. This Region also has a dry ditch policy where 
we allow a discharge from a tertiary (extended aeration, 
filtration, disinfection and multi point alum injection) 
treatment plant to a stream that seasonally goes dry. It is 
our philosophy that some water (nontoxic) in a ditch or 
stream is better than no water in the ditch or stream. It 
is up to the consultant to confirm the proposed approach is 
applicable for the discharge and always has the option of 
going out and collecting real streamflow data. 

Knowledge of background water quality is just as 
important as knowing estimated streamf lows. Upstream 
concentrations of total ammonia, temperature, pH, BOD5, 
suspended solids and total phosphorus are required to 
determine impact from the proposed discharge. If there is 
no water quality data available for your location you may 
have to estimate it from a nearby station or again collect 
your own. You should be aware of seasonal variation, the 
range of the parameter of concern and how the chemicals 
interact. Depending on the type of discharge, additional 
data on metals, phenols etc. may be required. Discuss the 
available data and explain the way you chose specific values 
to represent the water quality present in the stream under 
your discharge scenario. 

From here one can quite easily work backwards from 
required stream concentrations to required discharge 
concentrations by mass balancing or modelling under many 
different discharge scenarios. If using modelling 
techniques, unless you have real data for the variables, 
keep the model simple. You might as well estimate the 
answer if you are going to estimate all the input parameters 
and variables. Again the approach is up to the consultant 
but an explanation of why this approach is as good as or 
better than another is required. This automatically leads 
to the type of treatment process required to meet the 
required discharge concentrations under different discharge 
timing options. The list of treatment process options may 



- 6 - 



included but not limited to: facultative lagoons, aerated 
lagoons, activated sludge, extended aeration, filters, 
Sutton concept {extended aeration plus polishing ponds) , 
RBC's or a combination of the above. Storage requirements 
can be calculated along with discharge to streamflow 
scenarios using daily, weekly or monthly adjustments. 

Preliminary cost estimates for the different processes 
and discharge schemes that provide acceptable effluent 
quality can then be worked out by the applicant. A 
preferred option listing treatment process, storage and 
discharge timing can then be forwarded for review. You may 
have noticed that the consultant or applicant has done most 
of the estimating or documenting of impact to this stage. 
It is very important that the consultant knows the rules 
prior to getting to this stage so they know what information 
will be required for the Certificate of Approval. Once we 
receive the report, the Ministry will review all the data 
supplied and approaches used to arrive at the preferred 
alternative. This should be a relatively simple job if the 
consultant has followed the recommended approach. Based on 
this review one of four options will be recommended: 
1/ A conditional Certificate of Approval be issued where the 
system has a defined time frame to get into compliance. 
These are mainly used on innovative approaches where 
insufficient data is available to confirm the concept will 
work. If they are not in compliance by a set date, they 
must revert to a more conventional system. 
2/ A fixed time frame Certificate of Approval be issued 
where the C of A expires on or before a certain date. This 
approach is used for staged expansions and allows us to 
force the completion of the following stages. 
3/ A full Certificate of Approval be issued and this will 
not change until the average daily flows listed are exceeded 
or a major change in Ministry policy takes place. 
4/ Rejection of the full report and the suggestion that the 
consultant start over again. This should not happen if the 
consultant has been in contact with this Ministry through 
all stages of the process. 

For either of the first three options, effluent 
criteria for the proposed discharge will be developed by the 
Region based on both stream criteria and what the 
recommended treatment process should produce. This will 
confirm that whatever treatment process is recommended, it 
will be operated as efficiently as possible. The 
Certificate of Approval will included: information on the 
design (structures) along with recommended design values. 
These are suggested criteria that the treatment plant should 
try to achieve. It is nearly impossible to achieve monthly 
average total phosphorus concentrations of 1 mg/1 if you 
only design for that level. Also, monthly average 
non-compliance criteria and single sample maximum 



- 7 - 



non-compliance criteria are given. This forces the 
treatment process to produce consistent results and not 
allow short-term discharges of toxic materials. It makes 
little sense to protect a stream from toxics "on average". 
Information on monitoring and reporting requirements is also 
given to document how the treatment system is operating. 
Rationale for the effluent limits are given along with 
discharge limits before the system must come up for review 
or expansion. Other requirements may be also added to the 
Certificate of Approval. 

In summary, it is very simple to understand the need 
for good frequent communication between the applicant and 
the Regional Office of this Ministry. The obtaining of 
stream-based criteria upfront is necessary before any 
treatment process can be evaluated. Confirm your approaches 
as you go and there should be no misunderstanding at the 
time the report is submitted for a Certificate of Approval. 



- 9 - 

METAL FINISHING INDUSTRY POSITION 
By: Kenneth Coulter, P.Eng. 

Canadian Association of Metal Finishers 

The Canadian Association of Metal Finishers has been in existence for 
three years and represents a group of companies in the metal finishing 
industry. It is comprised of 40 companies with a combined total of 3500 
employees. Because it is new it is still growing. It limits its member- 
ship to companies who either have waste treatment facilities in place or 
are In the process of installing them. 

Some of the members are quite large companies with only a portion 
of their operation in metal finishing, while the majority are specialists 
in metal finishing as a service to other industries. Most of these are 
referred to as Job shops and are owner operated. Some companies employ 
as few as 10, while others employ 100' s. 

The processes of the industry include electroplating of various 
kinds, painting, hot dip galvanizing, electroless coatings, anodizing 
of aluminum and chemical conversion coatings. Many of these disparate 
processes are contained in the same facility. 

These processes are indispensable to the automotive, aerospace, 
electronics, fasteners, furniture, electrical, appliances, agricultural 
implements, transportation, jewelry and recreational industries. 

While the public awareness of the industry is mostly confined to the 
cosmetic aspects of its work, this represents only 15% of its activity. 
Of far greater importance is its value in providing corrosion protection, 
conductivity, paintability, solder ability, etc. 

The industry first became aware of its impact on the environment 
when companies were given incentives to locate in rural or semi rural 
areas of Ontario in the 1950' s. In many of these areas the sewage 
treatment systems were non-existent or inadequate. As a result, many of 
these plants found themselves having to discharge directly to water bodies. 
The Ontario Water Resources Commission worked with them to try to overcome 
the problems, but the lack of knowledge and availability of operable 
waste treatment equipment caused many difficulties. Some companies gave 
up or moved, others struggled and kept trying until some degree of control 
was in place. Most of the industry, however, was located in municipalities 
with sewage treatment plants. Each municipality had a different way for 
dealing with the industry. Unless a company actually dissolved a pipeline, 
they largely left the industry alone in the 50' s and 60's. 

Even as late as the mid seventies, when Environment Canada arranged a 
seminar jointly with the American Electroplaters Society in Toronto, 
bringing some of the top people from Europe to show the best available 
technology at that time, none of the invited guests from municipalities 
came. 

The preparation of the model by-law in 1975 did bring some effort toward 
enforcement from the municipalities but the degree of control exercised 
varied tremendously from region to region. The industry was aware, however, 
of the impending necessity to begin to practice more prevention of losses 
of potentially hazardous material to the sewer systems. Most companies 



- 10 - 



introduced various recovery systems into their processes and in general 
reduced losses to the sewers by 75-802 and introduced pH control in the 
majority of cases. 

When the 1975 model by-law was put in place and inspection systems 
set up, these reduced levels of contamlnents were found to be too high 
and treatment processes were introduced which destroyed cyanide, 
precipitated metals as the hydroxide and controlled spills and accidental 
losses. Recovery systems came on the market that not only limited 
discharge but recovered some materials for re-use. These included 
evaporators, De-ionization units, reverse osmosis and electrodyalysis . 
Some worked, others that worked were not economical. Newer equipment, while 
more effective has become more expensive. Substitution for toxic materials 
such as cyanide is now universal where it can. be applied. Metal hydroxide 
sludges which were originally disposed of with 97% water are now dewatered 
and sometimes dried to minimise volume. Pilot projects are underway to 
recycle nickle hydroxide, dried, and or fixed, through the refineries. 

One of the greatest difficulties in acquiring good pollution control 
in-plant has been the difficulty of training suitable operating staff. It 
usually requires a higher technical skill to run a treatment system than 
the process it is serving. Environment Canada, recognizing this problem, 
recently set up courses for the training of management, supervisors and 
operators, in the design, installation and operation of environmental 
control equipment. These courses were prepared with the assistance of 
various members of CAMF who also have served effectively as presenters. 

In spite of these efforts we have yet to reach the level of control 
where we are perfect 24 hours per day, 7 days a week. 

So far I have refrained from mentioning some of the companies in the 
industry with a much higher profile than the members of CAMF. The media 
have given them a great deal of coverage over their various legal battles 
vith municipal authorities. They are not members of our association, nor 
would we welcome them at the present time into our membership. 

There is a considerable spirit of co-operation within the Association, 
even amongst competitors when It comes to helping solve pollution control 
problems. The association will do everything it can to help a member who, 
while trying to meet the regulations finds himself in difficulty with an 
anomaly in his system. Similarly, the Association Is far more interested 
in working with the municipalities and Environment Ontario in protecting 
our waterways and treatment systems than being antagonists in legal actions . 
Far more will be accomplished faster following the route of mutual assistance , 

With that brief history of the industry out of the way, I would like to 
address our response to the recently published model sewer use by-law and 
the proposed MISA program of the Environment Ontario. 

The model sewer use by-law, recently made available to Ontario 
municipalities, Is, we understand, a bridge between the 1975 model by-law 
and the installation of the MISA program. 



- 11 - 



This by-law which we believe is already being introduced in a limited 
number of municipalities does address some of the concerns of the metal 
finishing industry, but at the same time effectively increases the inequity 
between municipalities that do enforce and those that do not. The MISA 
program which should bring about a much higher degree of fairness in 
enforcement is at least three years away from being in place. In the 
meantime industries who have millions of dollars in waste treatment are 
forced to compete with others, sometimes nearby, who have spent little or 
nothing on waste treatment. 

There seems to be a tendency on the part of the persons who have 
prepared this by-law to downplay the importance of this issue, even though 
the MISA document of September 1988 recognizes that it can be a matter of 
concern. Let me show you the costs as established in the United States 
and published in the April 1987 issue of Plating and Surface Finishing 
magazine. Costs, in Canada, are at least as high as in the United States 
as a percentage of the sales dollar. Charts #1 & 2. 

These charts show a wide variation in costs related to the size of 
the companies being reported. A recent Canadian installation in a job 
shop cost $170,000 for a plant using 80,000 gallons (Imperial), having a 
sales of CAN. $1,800,000 per year. It's operating cost of waste 
treatment including the same elements as the American chart amount to 
$131,000 or 7.3% of sales. However, only 60,000 gallons of water use 
and $1,000,000 sales are related to production that requires treatment. 
Thus the cost of treatment is 13.1% for these product lines. 

We are particularly anxious to show that using STATSCAN or other 
national averages do not show the economic impact on individual sectors 
of this industry. Captive shops are unlikely to report sales of their 
metal finishing operation only. 

while the MISA program suggests that accelerated write-offs will be 
available both federally and provincially, these are needed to permit the 
replacement of waste treatment equipment, which is proving to have a 
shorter life than the process equipment that creates the necessity for 
treatment. 

This problem is not a new one since I can remember a meeting of the 
Eastern Canada Region of the American Electroplating Society in nearby 
Breslau when a Kitchener plater was very eloquent in his complaint that 
he had to treat his waste when his competitors in Waterloo did not. That 
was over 20 years ago. 

With the new by-law In place we will see a great many more court 
actions with "not guilty" pleas. The very much higher maximum fines 
called for will see very few guilty pleas when grab sampling has been the 
basis on which a charge is made. We understand that grab sampling greatly 
simplifies the determining of non-compliance by a metal finisher, but, it 
can grossly exagerate the seriousness of the offence. As an example I 
would like to show the results of a 35 day study made at a facility which 
has installed the best available technology and has given It careful 
supervision with a high level of technical skill. Figure 1 shows the 
daily average discharge of this plant for the 35 day period compared 



- 12 - 



with the municipal by-law limitation of 5 mg/1. If the company's discharge 
had been at the limit permitted on average it would have discharged 2.21 
kilograms of zinc over a sixteen hour period. The actual overall discharge 
over the period was only 1.3 kilograms per day. When we look at a specific 
two day period within this study we see in Figure 2, that an anomaly 
occurred for a short period of time. Assuming that the period of non- 
compliance was three hours and that the average discharge was 3 mg/1 over 
the limit, the actual excess of zinc discharged was 185 grams total for 
three hours on the first day and 308 grams total on the second day. 

Both the existing by-law and the proposed model by-law provide for 
grab samples. This example shows clearly how grab samples distort the 
actual performance of the company in its efforts to meet the requirements 
that protect the sewer system, the safety of the workers in the system 
and the operation of the treatment plant. We note that the proposed 
by-law in its guidance manual provides for the possibility of sample 
averaging and the use of proportional flow sampling devices. We would 
prefer that these latter methods be used exclusively and will co-operate 
in any program, as is also suggested by the model by-law that would 
have industry instal such equipment and submit reports as necessary to 
the appropriate authority. Such reports, would, of course, be subject 
to confirmation by the authority. 

The guidance manual indicates that sampling will be done during 
regular working hours of an industry, but the most serious hazard for 
a sewage treatment plant is the concentrated dump that is usually made 
outside of regular working hours by a plating plant. If there is no 
treatment system in place these dumps have only one place to go and 
a grab sample will never pick it up . 

Returning to the examples shown above, we would like to bring 
attention to an anomaly in the by-law in that it penalises a company 
for any program for the reduction of water use. The by-law prohibits 
the use of dilution with water as a means of meeting discharge limits. 
However, if a company reduces its water consumption it must also reduce 
the amount of restricted matter in its effluent. 

The above company produces a quality of water from its final treat- 
ment system that permits it to return 402 to its rinsing system. It 
would seem that it is doing a great service to the sewage plant by 
reducing the hydraulic load on the system. If it is possible, as the 
guidance manual suggests to determine if a company is adding water for 
dilution by checking its records, it must be equally possible to determine 
the amount of reduction when it occurs and to make a contractual 
arrangement to permit the company to have 40Z greater level of metals 
in its effluent for compliance on the restricted material. 

The steps proposed in the guidance manual for a series of warnings 
to a company out of compliance are acceptable to our members and would 
be an improvement on some procedures that have been used in the past. 
While it might not have been the official policy of a municipality, 
some inspectors have not followed all of the steps proposed. The guide- 
lines also recommend that the inspectors encourage industry to take a 
split sample when sampling is being done. This, we not only encourage 
but cheer. Too often our members have been refused a split sample 
when they have asked for it and on many occasions the sampling is done 
without informing the company. 



- 13 - 



There are some areas in the new model by-law that will need 
clarification and we are not sure whose interpretation will carry final 
authority but I will not deal with them at this time. 

The MISA program provides us with some encouragement that our concern 
for uneven and unfair enforcement in Ontario will be addressed. There 
appears to us much yet to be settled, including the method of financing 
the program and that the proposed time table may not hold. The recognition 
in the Environment Ontario publication "Controlling Industrial Discharges 
to Sewers" under the heading Resource Limitations is most welcome. The 
time-table indicated in this document would seem to give Environment Ontario 
authority to correct the present inequities by late 1989 and we sincerely 
hope that this schedule will be maintained. 

The results of the study done for the Ministry by M. M. Dillon, as 
reported in the above document indicates that the sewer use control program 
in the United States is the most suitable option for use in Ontario. This 
does not present a serious problem for us provided we do not get into 
lock-step with the U.S. and make the same mistakes that they did. Some 
programs in the United States have proved unworkable and others have put 
an unnecessary burden on industry without appreciably improving the 
operation of their POTW's. 

We note that the ministry will set provincial regulations for each 
industrial sector imposing standards based on BATEA - Best Available 
Technology Economically Achievable. The Ministry is correct in assuming 
that what is BATEA for one industry may not be appropriate for another. 
This is also true within the metal finishing industry, since what is 
appropriate for a metal finisher with one or two elements requiring control, 
may not be appropriate for another with six or seven elements to control. 

We appreciate that economic studies for each industry will be completed 
prior to the promulgation of BATEA regulations and we hope that these are 
carried out without bias and with the searching out of all pertinent 
Information. The participants and process by which the Ministry will 
arrive at BATEA for each industry will apparently include such organizations 
as CAMF and we will be pleased to bring sources of verifiable information 
to the process. We presume that we would be included in the sub-committee 
membership for our industrial category. A very valuable conduit for 
information on the metal finishing industry is the American Electroplaters 
and Surface Finishers Society. This Society is a non-profit technical 
and educational society made up of over 8000 individual members. There 
are no company memberships. Its membership includes metal finishers, 
consultants and suppliers of both equipment and chemicals to the metal 
finishing industry. It meets annually with the American EPA in a 
co-sponsored three day seminar in January and organizes the largest 
conference for the industry each June. Within its membership there is 
to be found the greatest concentration of knowledge in North America on 
pollution control for this industry. 

The Society operates training programs for waste management 
operators throughout the United States and are now in discussion with 
another province concerning a program in Canada. 



- 14 - 



The Society is continuously financing research prograns such as one 
recently finished at the Ontario Research Foundation which investigated 
the most successful recovery systems available to the industry in Canada. 
This study was jointly financed by the Ontario Waste Management Corporation, 
The resulting report was the most sought after document of any of the 
previous research projects of the Society. Most of the members of the 
CAMF are contributors to this research program. 

In conclusion I would like to emphasize that the members of the 
Canadian Association of Metal Finishers is both a responsive and 
responsible group of companies. When we have our opportunity to 
contribute to the sub-committees studying our industry we will present 
factual, verifiable information and will assist the sub-committee in 
identifying suitable and acceptable sources of information. We will 
seek out Information where requested and will make ourselves available 
for any reasonable amount of time . 

WHILE WE SOMETIMES WONDER IF ANYONE LIKES US - WE DO KNOW WE ARE NEEDED. 



- 15 - 



EXTRACT FROM PLATING AND SURFACING FINISHING 
MAGAZINE APRIL 1987 



A SURVEY OF METAL FINISHING WASTEWATER 

TREATMENT COSTS 
BY DONALD P. DUFFY, GREGOR E. NORGAARD 
AND JOEL M. SANDBERG 



ALL FIGURES IN U.S. & U.S. GALLONS 



TYPE OF 
OPERATION 



PROCESS FLOW 
GAL/DAY 



TOTAL CONC. OF 
TREATMENT PLANT INFLUENT 
Metals Cyanide Chromium 



#1* JOB PLATER 



7,000 



63 



9 



#2 JOB PLATER 



#3 CAPTIVE PLATER 



#4 CAPTIVE PLATER 



#5 CAPITVE PLATER 



#6 P.C. JOBSHOP 



#7 JOB PLATER 



#8 CAPTIVE PLATER 



10,000 
13,500 
15,000 
28,000 
36,000 
45,000 
65,000 



37 


3 


7 


306 


11 


22 


13 


1 


0.75 


5 





3 


30 








106 


14 


9 


90 





15 



- 16 - 



ANNUAL WASTE TREATMENT COSTS 



TOTAL DISPOSAL DEPRECIATION 

INSTALLATION " OF AND 

COST CHEMICAL LABOUR SLUDGE OTHER TOTAL 



#1 19,300 8,462 25,284 6,000 5,146 44,892 

#2 100,000 10,882 14,872 35,640 20,300 81,694 

#3 430,000 11,300 116,551 36,792 90,000 254,733 

#4 250,000 5,216 42,312 19,402 65,750 132,680 

#5 200,000 6,653 11,610 23,220 56,600 98,083 

#6 477,000 16,495 17,280 27,360 97,751 158,886 

#7 200,000 21,084 31,381 32,076 41,100 102,761 

#8 120,000 50,357 39,330 30,444 35,560 156,691 



* THIS IS A BATCH TREATMENT OPERATION 

ALL OTHERS ARE CONTINUOUS FLOW AND AUTOMATED 



rj 



\n 






OS 




- Z.T - 



10 SAMPLINGS OF ZINC OWE TWO DAIS 




i- 
oo 



- 19 - 

POLLUTION CONTROL PLANNING 
AND BASIN MANAGEMENT IN THE 
REGION OF WATERLOO 



by 



G. Zukovs, S.G. Nutt and G. Godin 

CANVIRO Consultants 

Waterloo, Ontario 



INTRODUCTION 

The Regional Municipality of Waterloo is experi- 
encing an unparalleled period of industrial, commercial and 
residential growth. This growth has placed a significant 
burden on all facets of the municipal infrastructure, in- 
cluding sewage collection and treatment. At the same time, 
increasingly stringent effluent quality requirements for 
conventional and trace contaminants, fueled by concerns re- 
garding receiving water quality, have placed an additional 
burden on the existing municipal waste water treatment fa- 
cilities. Large capital expenditures will be needed to 
maintain the existing level of service without impeding the 
rate of growth in the Region or adversely impacting on the 
environment. 

In recognition of the need for capital expenditure 
and the necessity to ensure that such expenditures were ju- 
diciously managed, the Region undertook a study aimed at 
establishing a systematic plan for the orderly expansion and 
upgrading of the waste water treatment plants (WWTPs) in the 
Region over the next 30 years. This paper presents an over- 
view of the planning procedures used and the approach taken 

to establish short-term and long-term facility expansion re- 

(1 2J 
quirements ' . 



- 20 - 
BACKGROUND AND OBJECTIVES 

The sewage treatment requirements of the Regional 
Municipality of Waterloo are provided by eleven WWTPs as 
identified in Table 1. These facilities discharge approxi- 
mately 162,500 mVd of treated effluent to the Grand River, 
either directly (Kitchener, Waterloo, Preston, and Gait 
WWTPs) or indirectly via the Speed River (Hespeler WWTP) , 
the Conestogo River {St. Jacob's WWTP), the Nith River 
(Welles ley, Baden, New Hamburg, and Ayr WWTPs) and the 
Canagagigue Creek (Elmira WWTP) . 



Table 1 
TREATMENT FACILITIES LOCATED IN THE WATERLOO REGION 



HHTP 


Service Area 

Population 

(Dec. 31, 1986) 


Type of Treatment 


Rated Capacity 
(a 3 x lOOO/day) 


Kitchener 


149,988 


Conventional Secondary 


123.74 


Waterloo 


72,438 


Conventional Secondary 


45.46 


Cambridge (Gait) 


48,501 


Conventional Secondary 


38.641 


Cambridge (Preston) 


17,734 


Conventional Secondary 


16.866 


Cambridge (Hespeler) 


10,636 


Modified Secondary 

(High Rate Activated Sludge) 


9.319 


Elmira 


7,361 


Conventional Secondary and 
Tertiary 


4.545 


New Hamburg 


4,496 


Aerated Lagoons 


2.296 


Ayr (West Dumfries) 


1,448 


Extended Aeration 


1.181 


St. Jacobs 


1,345 


Oxidation Ditch 


0.954 


Baden 


1,083 


Extended Aeration 


0.923 


Nellesley 


1,008 


Extended Aeration 


0.50 



The Grand River Basin has been the subject of ex- 
tensive investigation under the Grand River Basin Water Man- 
agement Study* '. This study identified serious concerns 
with respect to total phosphorus loadings, un-ionized ammo- 
nia concentrations and oxygen-demanding carbonaceous and 
nitrogenous materials from municipal sewage treatment plant 
discharges. In addition, the high industrial contribution 



- 21 - 

to the Elmira WWTP produces concerns with respect to dis- 
charges of phenolic compounds. Some river reaches have also 
been identified as areas of water quality concern because of 
toxic substances, suspended solids, trace contaminants and 
bacteria. 

Addressing the identified water quality concerns 
in the receiving streams was an objective of the 30-Year 
Plan for Wastewater Treatment in the Region, as was address- 
ing the new and proposed effluent regulations which were ex- 
pected to have an impact on the capability and capacity of 
the existing facilities. Specifically, the objectives were: 

1) To review the operational status of each WWTP with 
respect to process and mechanical equipment, hy- 
draulic and organic loading conditions, and per- 
formance . 

2) To forecast loading conditions (hydraulic and or- 
ganic) to the end of the 30-year planning period 
(2017) . 

3) To review the current effluent quality require- 
ments and to estimate the ultimate effluent qual- 
ity requirements for each WWTP and to determine 
the impact of these requirements on plant capacity 
and the potential for plant expansion. 

4) To assess the implications of extraneous flows due 
to infiltration/ inflow (I/I) on the hydraulic ca- 
pacity of the WWTPs . 

5) To develop a systematic plan for expansion and, 
where necessary, upgrading of the WWTPs in the 
Region to meet growth requirements, and to develop 
current and future performance objectives for the 
duration of the 30-year planning period. 



- 22 - 

APPROACH 

In order to develop the 30-Year Plan for the Re- 
gion, each WWTP was subjected to a detailed review of his- 
torical performance over a two-year period to determine pre- 
sent hydraulic and organic loading conditions and to estab- 
lish performance characteristics. Onsite plant surveys were 
undertaken at all facilities to define process, mechanical, 
and physical upgrading requirements. At the larger facil- 
ities (Kitchener, Gait, Preston, and Hespeler) , detailed 
process audits were performed to establish plant capacity. 

Details of the procedures used during these process audits 

f 4 5) 
have been presented elsewhere v ' . Briefly, the audits in- 
volved detailed monitoring of process conditions using on- 
line instrumentation and automatic data acquisition equip- 
ment to establish dynamic patterns in the process and to 
allow an assessment of hydraulic and organic load limita- 
tions in the facility. Oxygen transfer measurements on ex- 
isting aeration hardware were a key component of these pro- 
cess audits. From the data generated, an accurate estimate 
of plant capacity could be made and the need for upgrading 
and expansion to handle future loads could be defined. An 
audit was not conducted at the Waterloo WWTP, the second 
largest facility in the Region, because it was already at 
hydraulic capacity and undergoing expansion. 

Future flow and load projections were developed to 
the year 2017, based on Regional and local Planning Depart- 
ment population forecasts and 1986 per capita flow and load- 
ing data. Adjustments were made to account for abnormal in- 
dustrial growth where appropriate. 

In conjunction with the MOE, future effluent qual- 
ity requirements were developed for each WWTP. The water 
quality management objectives stated in the MOE Blue Book 1 
formed the basis for establishing future allowable receiving 
water loadings from each WWTP. The Grand River Simulation 
Model (GRSM) was employed to assess water quality impacts 



- 23 - 

and allowable loadings for WWTPs discharging to the Grand 
River. Other more conventional modelling techniques were 
employed to estimate impacts and allowable loads for the 
other WWTPs. 

Statistical analysis of WWTP flow records, along 
with a review of previous collection system studies, were 
used to estimate the extent of I/I problems at each facil- 
ity. The economic ramifications of I/I removal from each 
collection system were estimated based on the proportional 
reduction in the variable O&M costs for that facility. 

From these analyses, upgrading and/or expansion 
requirements at each WWTP were established. In each case, 
maximizing the use of existing facilities was emphasized. 
Where appropriate, allocations of discharge loadings between 
WWTPs on the same receiving stream were considered to maxi- 
mize basin assimilative capacity while minimizing overall 
capital expenditure. In situations where space or receiving 
water quality constraints were identified, alternative 
approaches, such as combining flows from smaller WWTPs for 
treatment at a central facility, were evaluated as a means 
of maintaining waste water treatment service. Capital and 
O&M cost estimates were developed for all projects identi- 
fied, including up-front study costs. The individual WWTP 
project costs were amalgamated into a Region-wide 30 -Year 
Plan according to the priorities assigned to each individual 
project. The 30-Year Plan developed by this approach was 
intended to forecast key events related to waste water 
treatment services in the Regional Municipality of Waterloo 
and to provide budgetary cost estimates for fiscal planning 
purposes. 

STATUS OF WWTPs IN THE REGION 

Several of the WWTPs in the Region were undergoing 
upgrading or expansion due to capacity or performance limi- 
tations identified prior to the start of the plan develop- 
ment stage. The status of the Region's facilities at the 



- 24 - 

start of the Plan development stage is briefly summarized in 
Table 2. Notable projects that had already been identified, 
and to which capital funds had been committed, included up- 
grading of the Hespeler and Kitchener WWTPs, and expansion 
of the Waterloo WWTP. 

Tabic 2 
STATUS OF WWTPs IN THE REGION 



Facility 



Status 



1. Kitchener 

3. Waterloo 

3. Gait 

4 . Preston 

5. Hespeler 



6. Elmira 

7. Nev Hamburg 

8. Ayr 

9. St. Jacobs 

10. Baden 

11. Wellesley 



At 54 percent of design capacity. 

Upgrading of RAS/HAS metering and control being implemented. 

Installation of DO aonitorlng and control In progress. 

Expansion underway to increase capacity to 73.7 x 10 3 «Vd. 
Collection system study underway. 

Expansion/upgrade anticipated in 1968/89. 

At 53 percent of design hydraulic capacity. 

Organic overloading from local industries identified. 

Improvements in aeration and raw sewage pueping being 
implemented. 

Additional need for secondary clarification contingent on per- 
formance after initial modifications. 

Severe I/I problems in collection system. 
Plant approaching rated capacity. 

Experiencing I/I difficulties. 

Anticipate adequate capacity to beyond 3017. 

Hydraullcally and organically overloaded. 

Experiencing I/I difficulties. 

At rated hydraulic capacity. 

Collection system study in progress and I /I reduction being con- 
sidered. 



- 25 - 

As shown in Table 3, it was identified that sev- 
eral of the Region's WWTPs would be subject to more strin- 
gent effluent requirements than specified in MOE's Policy 
08-01 and Policy 08-04 within the 30-year planning period. 
These restrictions generally applied to discharges of phos- 
phorus and ammonia. Specifically, phosphorus removal to 
levels of less than 1 mg/L would be required at Kitchener, 
Waterloo, Gait, and, seasonally, at Hespeler. Ammonia re- 
moval requirements would apply at Kitchener, Waterloo, Gait, 
Preston, Hespeler, New Hamburg, St. Jacobs, and Wellesley. 
The projected lowering of effluent objectives for the Elmira 
WWTP were based on maintaining the same receiving water 
loads for B0D c , TSS, phosphorus, TKN, ammonia, and phenol at 
the projected future plant discharge of 5.8 x 10 3 m'/d as 
were presently required for flows up to the rated capacity 
of 4.545 x 10' m*/d. These specific water quality-based 
effluent objectives would be over-and-above the requirements 
to achieve the BOD,., TSS, and TP objectives outlined in 
Policies 08-01 and 08-04 on a monthly basis, and the impend- 
ing requirements of MOE's MISA program. 

The compliance status of these facilities, based 

on MOE's Report on the 1986 Discharges from Municipal Waste- 

(7) 
water Treatment Facilities in Ontario is summarized in 

Table 4. With the exception of the Hespeler WWTP, all fa- 
cilities were in compliance with annual BOD- and TSS objec- 
tives. Non-compliance with monthly TP objectives occurred 
at Waterloo, Preston, Hespeler, Elmira, St. Jacobs, Baden, 
and Wellesley. Of these, all WWTPs except Elmira and Hes- 
peler achieved an annual average of 1.0 mg/L TP or less. 

KEY FINDINGS OF THE 30- YEAR PLAN 

Major capital projects were forecast for all fa- 
cilities in the Region within the 30-year planning period, 
with the exception of the Ayr WWTP where only equipment re- 
placement costs were identified. At two other facilities 
(New Hamburg and Baden) , the timing and extent of future 



Table 3 
ANTICIPATED WHTP EFFLUENT OBJECTIVES 





Rated 
Capacity 
(10*aVd) 


1986 
Average 

Flow 
(10 a a s /d) 


2017 
Design 
U0*a J /d) 


Receiving 

Stream 




Anticipated Design Objectives * 








Facility 


BOD 5 


ss 


Total P 


TKN 


Total 
Ammonia 


Total 
Phenols 
(ug/D 


Total 
Residual 
Chlorine 


Total 

Conforms 
{org/ 100 eL) 


Comments 


Kitchener 


122.74 


63.4 


96.7 


Grand River 


15 
15 


15 
15 


0.7 
0.66 


m 


2.0 
1.9 


— 


_ 


- 


to 90.9xlO»aVd 
to 96.7xlQ*aVd 


Waterloo 


45.46 


46.1 


78.3 


Grand River 


15 
15 
15 


15 
15 
15 


0.80 
0.60 
0.55 


- 


1.8 
1.7 


* 


0.5 
0.5 
0.5 


200 
200 
200 


to 54.6xl0*aVd 
to 72.7xl0*aVd 
to 78.3xlO*aVd 


Gait 


38.641 


30.1 


48.0 


Grand River 


15 


15 


0.6 


- 


2.0 


- 


- 


- 


to 61.4xlOHVd 


Preston 


16.866 


8.9 


3.4 


Grand River 


15 
15 


15 
15 


1.0 

1.0 




15 
2 to 4 


- 


M 


m 


to 16.9xlOVaVd 
to 34x1 s /d 


Hespeler 


9.319 


5.48 


9.9 


Speed River 


15 
15 


15 
IS 


0.66/1.0 
0.50/1.0 


- 


4.0 
3.0 


- 


0.5 
0.5 


200 
200 


to 13.6xl0V»Vd 

to 18.2xl0 3 mVd total P 

Kay 1-Sept 30/ 

Oct 1-Apr 30 



Elalra 



4.545 



3.98 



5.0 



Canagaglgue 7.5 15 1.0 3.5 7.5 6.5 
Creek 



5.5 11 



0.7 2.5 5.5 



5.0 



to4.5xl0*aVd 
TKN- Apr 1-Oct 31 
NHj-N-Nov 1-Har,21 
to S.BxMPm'/ir" 
TKN-Apr l-0ct 31 
MHa-N-Nov 1-Mar 31 



New Hamburg 



2.296 



1.69 



2.0 



Nlth River 15/30 15 



1.0 



8.0 



3.0 



to 2.3xl0 J aVd vill re- 
quire 217,000 a* of 
storage & streaaflow 
proportional discharge 
BOP. Hay-Oct/Nov-Apr 



*!£_ 



1.181 



0.40 



0.80 Nlth River 



15 



15 



1.0 



to 1.2xl0 3 eVd 



St. Jacobs 



Baden 



Hellesley 



0.954 



1.130 



1.70 



Cones togo 
River 



15 



15 



1.0 



15/5 



0.923 



0.68 



0.87 



Baden Creek 15 



15 



1.0 



0.50 



0.64 



0.896 Nlth River 



15 



15 



1.0 



5.0 



* All units in mg/L unless otherwise stated 



to 1.82xl0*aVd 



to 0.92xlO s a 3 /d stream 
water quality poor; HOE 
desires no additional 
loadings 



to 1.09xl0*B.Vd will 
require Bl.SxlO^a* of 
storage £ streaaflow 
proportional discharge 






(KIA2/109W) 



- 27 - 







Table 


4 








COMPLIANCE STATUS OF REGION'S WWTPs 












Compliance Status* 




Facility 


BOD 






TSS 


TP 


Kitchener 


Yes 






Yes 


Yes 


Waterloo 


Yes 






Yes 


No (2) 


Gait 


Yes 






Yes 


Yes 


Preston 


Yes 






Yes 


No (3) 


Hespeler 


No 






No 


No (8) 


Elmlra 


Yes 






Yes 


No (8) 


New Hamburg 


Yes 






Yes 


Yes 


Ayr 


Yes 






Yes 


Yes 


St. Jacobs 


Yes 






Yes 


No (4) 


Baden 


Yes 






Yes 


No (4) 


Welles ley 


Yes 






Yes 


No (1) 



Notes: * BOD and TSS based on annual average requirements. 
TP based on monthly requirements. Number of months 
out -of -compliance is shown in brackets. 



works was contingent on the success of efforts to remove ex- 
cessive amounts of extraneous flow from the collection sys- 
tem. The estimated capital expenditure (1987 dollars) re- 
quired to maintain service in the Region and to meet the 
anticipated effluent quality requirements which may be 
placed on the facilities was approximately $120 million, in- 
cluding $20 million in committed projects. The largest ex- 
penditures, exclusive of those already committed, were fore- 
cast for the Gait and Preston WWTPs. 

Capital expenditures were forecast as a result of 
both plant expansion requirements over the planning period 
and plant upgrading requirements to meet new or proposed 
effluent-quality objectives. Table 5 shows the major capi- 
tal works identified for facilities in the Region. Planning 
projections suggest that the Gait, Preston, Hespeler, 
Elmira, St. Jacobs, and Wellesley WWTPs will require expan- 
sion beyond their present rated hydraulic capacity before 
2017 to meet residential and industrial demands. In addi- 
tion, the Waterloo WWTP, which was undergoing expansion dur- 
ing development of the 30-Year Plan to increase its rated 



Facility 



1. Kitchener 



2. Waterloo 



3. Gait 



4. Preston 



5. Hespeler 



6. Elulra 



7. St. Jacobs 



8. Hellesley 



- 28 - 

Table 5 
PROJECTED MAJOR CAPITAL WORKS PROGRAMS 



Undertaking 



Timeframe 



- Digester expansion/upgrading 

- Aeration upgrade to achieve nitrification 

- Final effluent filtration 

- Final effluent filtration 

- Plant expansion and upgrade 

- Upgrade of aeration system 
* Plant expansion and upgrade 

- Upgrade of existing facility 

- Plant expansion and upgrade 

- Upgrade of existing facility 

- Plant expansion and upgrade 

- Plant expansion and/or effluent transfer 
to Grand River 

- Plant expansion, possibly in conjunction 
with Elmira 

- Plant expansion 



1994 
1994 
1994 

1991 
2004 

1989 
2000 

1990 
s 1995 

1988-1990 
2012 

1990 



1989 



1989 



capacity, would require a second expansion to further in- 
crease capacity before 2017. Thus, of the eleven WWTPs in 
the Region, seven would require expansion at some time dur- 
ing the planning period. Of these seven WWTPs, five facil- 
ities (Waterloo, Gait, Preston, Hespeler, and Elmira WWTPs) 
would also be subject to more stringent effluent regulations 
during the same 30-year time period. As a result, the capi- 
tal works projected for these facilities also included an 
upgrading component to increase plant performance from the 
standpoint of organic removal, phosphorus removal and/or 
ammonia-nitrogen removal. The Kitchener WWTP, which was 
projected to be operating at only 80 percent of present 
rated capacity at the end of the planning period, would 



- 29 - 

require capital works due entirely to increasingly stringent 
effluent quality objectives which would be applied before 
2017. 

In some instances, it was shown that large capital 
expenditures at one facility might by postponed or delayed 
by improvements made at another facility. For example, 
trade-offs were shown to exist between the Kitchener, 
Preston, and Gait WWTPs in terms of effluent load alloca- 
tions and Grand River water quality. Improvements beyond 
the maximum allowable effluent un-ionized ammonia concentra- 
tions or total phosphorus concentrations at one or two of 
these facilities could be traded against the effluent objec- 
tives required for a third facility. 

Treatment plant process audits undertaken at the 
larger facilities were also successful in identifying poten- 
tial avenues of capital cost saving through process optimiz- 
ation. For example, large capital expenditures had been 
originally forecast for the Kitchener WWTP to achieve the 
nitrification objective proposed. As part of the process 
audit, oxygen transfer tests demonstrated that the potential 
existed to achieve nitrification within the existing facil- 
ity by lower capital cost improvements to aeration hardware 
and implementation of dissolved oxygen monitoring and con- 
trol techniques. The in-plant tests demonstrated that ex- 
isting oxygenation capacity was adequate to beyond the year 
2000 and that minor upgrading could improve the transfer 
capability to meet demands for nitrification to near the end 
of the planning period. 

EFFECT OF EFFLUENT REQUIREMENTS ON THE PLAN 

New and proposed effluent requirements impacted 
significantly on the outcome of the planning process. As 
noted, six of the eleven facilities in the Region were sub- 
ject to more stringent effluent quality objectives because 
of water quality concerns. All facilities will be impacted 
by the change from the historical annual averaging of efflu- 



- 30 - 

ent quality for assessing to the monthly averaging and by 
the still undefined MISA requirements. It is difficult to 
break down the capital costs in the 30-Year Plan into com- 
ponents which were associated with expansion to meet capa- 
city requirements, with upgrading to maintain or meet pre- 
sent effluent requirements, and with upgrading to meet new 
and proposed effluent requirements. However, as a rough es- 
timate, up to 25 percent of the total capital expenditures 
forecast and committed may be directly associated with the 
new effluent requirements. These requirements could have 
been substantially higher without prudent evaluation of the 
capabilities of the existing hardware, and consideration of 
alternative approaches to meet water quality concerns. 

REFERENCES 

1. Canviro Consultants. A Thirty-Year Plan for Waste 
Water Treatment, Volume 1, Summary Report . Prepared 
for the Regional Municipality of Waterloo. November 
1987. 

2. Canviro Consultants. A Thirty-Year Plan for Waste 
Water Treatment, Volume 2 - Technical Report . Prepared 
for the Regional Municipality of Waterloo. December 
1987. 

3. Grand River Implementation Committee. Grand River 
Basin Water Management Study . 1982. 

4. Canviro Consultants. Evaluation of the Potential fo r 
Energy Savings and Nitrification at the Kitchener Water 
Pollution Control Plant . Prepared for the Regional 
Municipality of Waterloo and Environment Canada. No- 
vember 1986. 

5. Stephenson, J. P., S.G. Nutt, and G.W. Speirs. "On-Line 
Instrument and Micro-Processor Based Audit of Activated 
Sludge Systems". Presented at the Annual Conference of 
the Instrument Society of America ISA/87, Los Angeles, 
Ca. October 1987. 

6. Ontario Ministry of the Environment. Water Management 
Goals, Policies, Objectives and Implementation Proce- 
dures of the Ministry of the Environment . May 1984. 

7. Ontario Ministry of the Environment. Report on the 
1986 Discharges from Municipal Wastewater Treatment 
Facilities in Ontario. October 1987. 



- 31 - 



IMPACT ON DESIGN AND OPERATION OP 
MUNICIPAL TREATMENT PLANTS 



Steve McMinn, M.M. Dillon Limited - Design 

Bob Pickett, Metro Toronto Works Department - Operations 



DESIGN 

(a) GENERAL 

The Municipal/Industrial Strategy Abatement (MISA) initiative, combined 
with a generally increased stringency in effluent quality and in the definition 
of compliance, is changing the design process for all treatment facilities. 

As an example of the impact on small facilities, we can look at the Village 
of Lucan sewage treatment expansion project. Lucan is located 30 km 
north of London, and is only one of many small municipalities with similar 
projects now underway in South-western Ontario. 

The existing 13 acres of facultative lagoons which serve a population 
of 1,600 persons have been over capacity for some years now. The lagoons, 
originally designed for continuous discharge, were later designated by 
Ministry of the Environment (M.O.E.) as a seasonal discharge (twice per 
year) system. With a requirement to store and treat sewage without 
discharge from May until October, the lagoons actually fill and begin 
to discharge by July. Development restrictions on subdivision approval 
have been in place for a number of years, but additional flows from 
previously approved developments have compounded the problem. 

The lagoons discharge to an agricultural drainage ditch which then 
transports effluent approximately 1500 m to the Little Ausable River. 
The ditch and the river experience periods of zero flow. 

Stream quality degradation, as measured by free ammonia, Five-day 
Biochemical Oxygen Demand (BOD5L, Phosphorus (P) and Dissolved Oxygen 
Parameters, was attributable directly to seasonal discharge from the 
lagoons. 

By-passing of raw sewage was occurring at the single pump station in 
the Village and from at least one other location along the sewer system. 

Population projections for the Village indicated a considerable population 
increase and Village Council was in favour of growth. 



- 32 - 



Obviously, something had to be done to solve the environmental problem 
and meet the demand of increased population. 

Effluent guidelines were developed for the new 20-year population of 3,000. 
The new or upgraded facility would continue to discharge to the land 
drainage system. 



(b) EFFLUENT GUIDELINES 

(i) Biochemical Oxygen Demand (BOD) 

* Non-freezing period 5.0 mg/L 

* Freezing period 10.0 mg/L 

* Freezing: Average of Daily Mean Ambient 

Temperature equal to or less than 0°C 

Biological treatment alone cannot ensure that the non-freezing 
period criteria can be consistently achieved. Even appropriately 
designed, seasonal discharge facultative lagoons will not meet 
these criteria. Aerated lagoons would require a solids separation 
step, probably settling plus filtration. An activated sludge 
system will also require the filtration phase. 

(ii) Suspended Solids (S.S.) 

Non-freezing period 5 . mg/L 

Freezing period 10.0 mg/L 

The same considerations apply here as for the BOD5 
requirements. Assuming biological treatment, achieving the 
BOD5 criteria will also mean that S.S. goals will be met. 

(iii) Total Ammonia Nitrogen 

Non-freezing period 2 . mg/L 

Freezing period 4.0 mg/L 

This is the most influential determinant in treatment process 
selection. 

The efficiency of biological nitrification is dependent on, among 
other things, temperature, pH and Dissolved Oxygen 
Concentration. (Providing an adequate sludge age is, of course, 
a basic requirement). 



- 33 - 



Nitrification becomes temperature dependent at operating 
temperatures less than 12-15°C, severely inhibited below 
approximately 7°C and below 5°C almost non-existent. 

Of viable treatment systems, only the extended aeration and 
rotating biological contactor (RBC) options can provide the 
required level of nitrification during the freezing period. 
Lagoon technology is not suitable. 



(iv) Total Phosphorus 

Non-freezing period . 3 mg/L 

Freezing period . 8 mg/L 

This reinforces the need for effluent filtration, obviously 
demands high chemical addition and may require multiple 
point chemical addition. 



(v) Dissolved Oxygen 

Non-freezing period 5 . mg/L 

Freezing period 5.0 mg/L 

May require post aeration facility. 



(vi) E. Coli 

Non-freezing period 200/100 mL 

Freezing period 200/100 mL 

Disinfection, which to obtain non-toxic effluent cannot be 
by chlorination unless followed by dechlorination, will most 
likely be by UV disinfection. 



(c) OTHER DESIGN CONSTRAINTS 

(i) No By-Pass 

Smaller communities experience high peak to average flows. 
When combined with a leaky sewer system and interconnection 
with storm-type flows, it is appropriate to provide flow 



- 34 - 



equalization. This not only makes it more likely that the 
stringent effluent guidelines can be consistently met, but may 
allow reduction in the size of those plant processes (clarifiers, 
filters) that are sized for peak flows. 

(ii) Compliance 

As well as the requirement to meet more stringent effluent 
criteria, these criteria must be complied with on a more 
consistent basis than in the past. It is necessary to accept 
and treat (at least to primary level) all sewage which enters 
the sanitary sewer system, including in some cases, returned 
flows from combined sewer overflows- Some plants may be 
required to accept, and handle without passthrough, certain 
toxic parameters. Redundancy in unit processes, process 
controls systems, increased operator training, conservative 
design to accept peak flows and shock loadings all result from 
this more strict compliance requirement. 

(iii) MISA Regulations 

MBA regulations are not expected to further impact many 
of the small to medium facilities which are already subjected 
to strict effluent guidelines, particularly where industry is 
not a factor. Where toxic wastes from industry (non-categorical 
or SIDS) do pass through the municipal plant, further municipal 
treatment processes may be a local option. 

(iv) Discharge to Match Assimilative Capacity 

In general, the criteria considered in today's paper will permit 
continuous discharge even when zero flow is available in the 
receiver (in this case, a drainage course or small stream). 
The effluent is classified as non-toxic to aquatic life and 
available dilution is not considered as allowing for effluent 
to be of a reduced quality. 



(d) THE SELECTED DESIGN SOLUTIONS 

Abandon existing lagoons 

Flow equalization 

Extended aeration for nitrification 

Effluent filtration 

Ultraviolet disinfection 

Aerobic sludge digestion 



- 35 - 



The effluent criteria effectively excluded the lagoon option and 
required the higher cost solution, namely a mechanical treatment 
plant. Local conditions did not allow incorporation of the existing 
lagoons, even had they been shown to be of benefit. 



<e) THE POST-MORTEM 

Is the effluent criteria logical for a small municipality 
discharging to a sensitive receiver? 

Is the provincial grant money being effectively used? 

Are there less expensive, reliable treatment options (the "Sutton" 
concept)? 

Are individual project costs being assessed as part of an overall 
provincial expenditure? 

Should effluent guidelines which are provided by the Province 
need to be rigorously justified. 

Is lagoon technology now obsolete? 

Should more affordable techniques, such as wetlands, be 
implemented more aggressively, perhaps using special funding 
for innovative approaches. 



2. OPERATION 

(a) GENERAL 

Having dealt with some of the possible impacts that the new and 
proposed effluent guidelines will have on the design of municipal 
treatment plants, this portion of the paper wiU deal with some of 
the operational problems posed by these guidelines. 

In order to illustrate some of the operational impacts, we will 
introduce another treatment plant's Certificate of Approval which 
governs the effluent quality and the special conditions of operation. 

The plant selected is the Humber Treatment Plant located in 
Metropolitan Toronto. This activated sludge was commissioned 
in 1960. It has a present day capacity of approximately 410,000 
cubic metres per day and is being expanded to 473,000 cubic metres 
per day. The plant serves a population of 540,000 people and receives 
flows from residential, industrial and commercial sources. 



- 36 - 



Upon the expansion of the secondary treatment capacity from 
410,000 mVd to 473,000 m a /d in 1988, the plant was issued its first 
ever Certificate of Approval, with terms governing its effluent 
quality. 

The effluent objectives stated in this Certificate are not that 
comprehensive. 



<b) EFFLUENT OBJECTIVES 
(i) Design Objectives 

Effluent Parameter 

Total Phosphorus (P) 

Suspended Solids (S.S.) 

Five-day Biochemical 
Oxygen Demand (BOD5) 



Effluent 
Concentration 

1.0 mg/L 

15.0 mg/L 

15.0 mg/L 



Total Loading 
From Effluent 

172,000 kg/year 



(ii) Operating Objectives 

Effluent Parameter 

Total Phosphorus (P) 

Suspended Solids (S.S.) 

Five-day Biochemical 
Oxygen Demand (BOD5) 



Effluent 
Concentration 

1.0 mg/L 

25.0 mg/L 

25.0 mg/L 



Total Loading 
From Effluent 

172,000 kg/year 



The objectives do not seem particularly onerous, however, one cannot 
help noticing that Design Objective and Operating Objective for 
Phosphorus are equal. This situation cannot help but put extra pressures 
and demands on the operator to run the facilities exactly as designed, 
with no margins as provided for in the Suspended Solids and Five-day 
Biochemical Oxygen Demand limits. It should also be noted that the 
Phosphorus requirement is based on a monthly average whereas the 
Suspended Solids and the Five-day Biochemical Demand requirements 
are based on an annual average. 



- 37 - 



The special conditions of the Certificate call for the maintenance of records 
on all raw or partially treated sewage for all by-pass occurrences. As 
well the influent and effluent shall be analyzed for: 

Total Phosphorus (P) 

Total Kjeldahl Nitrogen (TKN) 

Ammonia Plus Ammonium Nitrogen 

Nitrite Plus Nitrate Nitrogen 

Five-day Biochemical Oxygen Demand (BOD5) 

Suspended Solids (S.S.) 

Chlorides 

Conductivity 

Total Conform Bacteria 

Fecal Coliform Bacteria 

Fecal Streptococcus 



These conditions are not particularly difficult to deal with given that 
there are laboratory facilities located at the treatment plant capable 
of handling this type of analysis. It should be noted, however, that 
conditions surrounding the recording of the by-pass occurrences, provides 
no relaxing of the effluent guidelines during these events. Nowhere in 
the Certificate is there a provision for an excursion caused by storm or 
wet weather flows. 

In order to more fully review the implications that these effluent guidelines 
will have on operations, we will lock at three areas: 

(1) Operations and Maintenance Procedures and Practices 

(2) Storm Flows 

(3) Costs 



(c) OPERATION AND MAINTENANCE PROCEDURES AND PRACTICES 

It is obvious that we will have to move from training by osmosis 
to training of a more formal nature. In order to demonstrate a due 
diligent defence, it must be shown that formal operating procedures 
are in place and that personnel are familar with these procedures. 
These procedures must be in a written form in order to ensure that 
there is no misunderstanding. Having said that these procedures 
must be written, this does represent a bit of a problem. If we were 
to review the operating manuals for a facility of the size of the 
Humber Treatment Plant, one could envision a manual the size of 
several encyclopedia. It is obvious that the manual itself will provide 
little protection if the people, who will have to use it, have not 
been trained. 



- 38 - 



Certainly, the Certification of Operators will provide us with a 
means of ensuring that all our operators are measured against a 
common yardstick. This is not to say that Certification by itself 
will solve the problem of qualified personnel. We must institute 
training programs which will ensure the operators are prepared to 
handle the problems they will face when operating the treatment 
plant. 

In order to have proper operations the facilities must be properly 
maintained. This will call for written procedures and schedules 
to ensure that the proper maintenance is being conducted. Here 
is another area where training will be required in order to ensure 
that the maintenance personnel are properly skilled. Part and parcel 
of the maintenance program will be the need to have stand-by 
equipment, to be put in service whenever maintenance will be required 
on the operating equipment. This is common practice in the Water 
Supply industry, where they have defined the "firm" capacity which 
recognizes the possible loss of equipment due to maintenance. 



(d) STORM FLOW 

I have deliberately put storm flow as a separate area to review 
because it is not handled in the Certificate of Approval governing 
effluent guidelines. In the previous section dealing with design, 
there is no provision for storm flow in the Certificate for the Lucan 
facilities. In the same fashion, the Humber Treatment Plant's 
Certificate mentions that records must be kept of the flows, quality, 
duration and volume, however, no provision is made in the effluent 
guidelines to exclude the storm flow data from the monthly and 
annual averages. If the intent is to provide the quality of treatment 
to all flows, then facilities will have to be sized for treatment of 
storm flows. The dilemma here is for what intensity of storm would 
you design? 



(e) COSTS 

Everything we have stated in the two previous areas has a cost 
associated with it, whether it is an operating cost or a capital cost. 
If we review the operating costs that will be experienced by these 
guidelines, there will be costs for training of personnel and for the 
trainers who teach the staff. As well, there will be extra staff 
required to cover the plant while some of the operators are at training 
courses. There will also be costs for the development of these courses. 
There will be a cost associated with the preparation of manuals. 
One example of these costs, we have received a cost for the 
preparation of a manual, for automated digestor operation at one 
of the Metro Toronto Plants, of approximately $30,000.00. 



- 39 - 



We must also consider the cost for doing the necessary effluent 
analysis. In the case of the Humber Treatment Plant, daily analysis 
is conducted on the influent and effluent for: 

Total Phosphorus (P) 

Total Kjeldahl Nitrogen (TKN) 

Five-day Biochemical Oxygen Demand (BOD5) 

Suspended Solids (S.S.) 

plus Ammonia, and Ammonium Nitrogen on the effluent only: 
Other analysis includes: 

Settled Sewage Suspended Solids and BOD5 

Mixed Liquor Suspended Solids 

Return Sludge Suspended Solids 

Primary Sludge Total Solids and Volatile Solids 

Thickened Waste Activated Total Solids and Volatile Solids 

Weekly Digested Sludge Total Solids and Volatile Solids 

Filter Cake Total Solids 

Filtrate Suspended Solids 

Monthly analysis influent and effluent for heavy metals 

Monthly analysis of digested sludge for heavy metals 

The present annual cost for our laboratory services is approximately 
$1,370,000.00. This is the cost to run five laboratories, one at each of 
the four treatment plants and our Industrial Waste Laboratory. We conduct 
approximately 127,000 analyses on 74,000 samples. We are presently 
expanding our Industrial Waste Laboratory and are adding the capability 
to do trace organics, with the exception of dioxins, furans and PCB's. 
The cost of the facilities is about $5,000,000.00, including the laboratory 
equipment. We will be able to conduct analysis for heavy metals, phenols, 
greases and oils, bacteriology and trace organics. 



- 40 - 



If we look at possible capital costs, the cost to handle wet weather flow 
at the Humber Treatment Plant is estimated to be $32,000,000.00, for 
an additional 59,020 m'/d of secondary treatment capacity. This figure 
was obtained from a recently completed study (Humber Sanitary Trunk 
Sewer System and Treatment Plant Study, July 1988, UMA Engineering Ltd.) 
on the Humber Treatment Plant. Even this figure is based only upon a 
five-year storm. 

The requirement for stand-by equipment for "firm" capacity during 
scheduled maintenance also has its associated cost. One can use the 
estimation of approximately $9.08 per litre for additional secondary 
treatment capcity or $18.16 per litre for primary plus secondary, when 
calculating the cost for stand-by facilities. 



(f) IMPACT OF MISA 

If we are to consider the imapct that MISA will have on the previous 
three areas of concern, perhaps the greatest impact will be on the 
analytical work that will be required. Presently, Metropolitan Toronto 
pays approximately $60,000.00 to sample four treatment plants' 
influent and effluent for heavy metals and trace organics. This 
works out to approximately $15,000.00 per plant per sampling. The 
forty plant studies conducted by the Ministry of the Environment 
(M.O.E.) cost approximately $2,000,000.00 for analysis of the influent, 
effluent and sludges, on two occasions per plant. Analysis was 
conducted for heavy metals, trace organics and the conventional, 
i.e. BOD 5 , S.S. TP, NH», N0 2 , TKN, Cl a . The M.O.E. has recently 
released a report on Laboratory Facilities capabilities to handle 
the MISA sampling (M.M. Dillon, July 1988). In this report, the cost 
for a Total MISA Characterization was broken down as follows. 

Low Median Average High 
$ $ * * 



1,247.05 3,509.35 4,042.78 11,701.70 

The report goes on t o say that they feel that there is sufficient 
laboratory capacity to handle the MISA analysis. 

My sense is that we will experience problems with the cost of the 
MISA sampling. Unless the M.O.E. provides some means of certifying 
the laboratories, we could have problems with data reliability. This 
complicated by delays in obtaining results. We can presently wait 
as long as three months from the time of sampling to receipt of 
a final report, this for just one sampling of the four plants. When 
this sampling frequency is increased, delays can only become more 
of a problem. 



- 41 - 



If we add the requirement to do Bio-Assay's, which is completely 
new to most, if not all the treatment plants, there will be a need 
to hire more staff to handle this load, or the work will have to be 
contracted out. 



(g) SUMMARY 

The new effuent analysis and the MISA program will require more 
formalized operations and maintenance procedures in order to ensure 
adherence to the guidelines. There will also be a requirement for 
better training. Certification of Operators is a way of ensuring 
an adequate standard of knowledge. 

Storm flow or by-pass caused by storm flow must be recognized 
in the Certificate of Approvals. To insist on no by-pass is simply 
ignoring the inevitable and would not stand up to the scrunity of 
cost benefit analysis. 

There must be redundant or stand-by equipment and tankage to 
permit regular maintenance of equipment without the loss of capacity. 
We must also deal with the problems that the MBA effluent analysis 
will bring. The cost is prohibitive and the ability of the laboratories 
to handle this load is questionable. 



- 43 - 



ABSTRACT ONLY 

THE USEPA TOXIC REDUCTIONS PROGRAM 

Henryk Melcer, of Environment Canada's Wastewater Technology 
Centre, stepped in at the last minute to present a paper on 
behalf of the United States Environmental Protection Agency, 
on their procedures to evaluate methods of measuring toxicity 
in municipal sewage treatment plant effluents. 

The paper also reported on a series of laboratory simulations 
which measured the effectiveness of different unit processes 
in removing toxicity. These processes included air stripping, 
filtration, adsorption and ion exchange. Extremely high 
removal rates were experienced when processes were run individ- 
ually or in series on target toxic chemicals. 



- 45 - 



THE IMPACT ON MUNICIPALITIES 



by: Clare Bauman, 

Regional Municipality of Waterloo 



I wish, first, to extend to you greetings from the Regional 
Municipality of Waterloo. I understand these one day seminars are 
usually held in Toronto. I hope you enjoy your brief stay here and 
that your deliberations today are profitable. 

I will give you a brief background profile of the Municipality to 

provide comparisons. The Regional Municipality of Waterloo is 

comprised of seven Municipalities, contains 519 square miles and 
approximately 325,000 people. 

The Region has 1,200 industrial and commercial enterprises which 
are served by separate storm and sanitary sewers. The waste water is 
directed to one of eleven waste water treatment plants before 
discharge to a receiving watercourse. The industrial base consists 
of the following major groups: 

i) food and kindred products, 

ii) textile, 

iii) beverage, 

iv) metal fabricating and finishing, 

v) chemical and allied products, 

vi) automotive, 

vi i ) f oundaries , 

viii) rubber and miscellaneous plastic products, 

ix) leather and leather products. 

but has industry in all catagories provided in the new model by-law. 



- 46 - 



Industrial discharge inspection, analysis, and enforcraent began in 
the Region in 1973. The Regional program is supported by a 
laboratory facility which provides the testing and reporting to local 
businesses . 

Statistics are: Staff: twelve 

Vehicles: four 
Lab Space: 7,500 square feet 

The operating budget for 1988 is $438,806.00. The Region anticipates 
revenue from industrial surcharges to exceed $1,250,000.00 in 1988. 

The proposed annual current and capital budgets are as follows: 

- Total current $17,307,000.00 which includes laboratory, waste 
water treatment and administration. 

- Total capital $17,799,000.00 which includes construction of a 
new laboratory at $3,300,000.00. 



OVERHEAD: WASTE WATER TREATMENT RATES (Table 1) 



c 
O 

"5 
O 

8 

O 



w 
Q. 



O 



210 



Regional Municipality of Waterloo 

Wastewater Treatment Rates 




T r~ -i 

1968 1989 1990 1991 



1992 



1993 



I 1 r 

1994 1995 1996 



1997 



Current Policy 



Year 



o Recommended 



TABLE I 



- 48 - 



This overhead shows the Waste Water Treatment Rates anticipated during 
the next ten years. The rapid rise is caused by capital projects, 
largely in waste water upgrades, expansions, and the significant 
impact of new criteria for waste water plant design and discharge. 
The total expenditure in capital projects over ten years is expected 
to exceed $100 million. 

I would like to examine the estimated Capital and Operating costs for 
enforcement as our Region forsees it, together with cost estimates in 
the Ministry of the Environment Discussion Paper "Controlling 
Industrial Discharges to Sewers". 



OVERHEAD: ESTIMATED ANNUAL MDNICIPAL OPERATING COSTS (Table 2) 



OVERHEAD : REGION OF WATERLOO ESTIMATED ANNUAL OPERATING 
COSTS (Table 3) 



The Region of Waterloo has an advanced program in place. We do not 
expect to receive a large amount of funding from the Ministry of the 
Environment to help us develop programs. 

However, the Region has received a committment for 1/3 funding of a 
new Regional Laboratory estimated to cost $3.3 million. This M.O.E. 
committment still leaves $2.2 million to be born locally. 



ESTIMATED ANNUAL MUNICIPAL OPERATING COSTS 


Cost Feature 


Current Cost 


Cost Under 
Proposed Program 1 , 2 , 3 


Total sewer use 
program cost per 
year 

Municipal personnel 
required 

Cost per capita 


$3,800,000 

95 

$0.54 


$20,600,000 

270 
$2.73 


Note: 

1 Total annual sewage servicing operating budget in 1985 
(excluding capital) in Ontario was $269,000,000. 

2 Total annual sewage servicing charges collected in 1985 
in Ontario was $231,000,000. 

3 Total annual municipal budget in 1985 (excluding 
capital) in Ontario was $6,513,000,000. 



10 



TABLE 2 



REGION OF WATERL OO ESTIMATED ANNUAL OPERATING COSTS 
Cost Feature 



Total sewer use 
program cost per 
year ' 

Municipal personnel 
required 

Cost per capita 



Current Cost 



$500,000 



12 



$1.42 



Cost Under 
Proposed Program 



$1,200,000 



26 



$3.43 



o 



TABLE 3 



- 51 - 



Municipal/Industrial Strategy for Abatement 

The Municipality will have to await the final Regulations for the 
Municipal Sector in order to fully access costs. However, if organic 
contaminants are as ubiquitous as heavy metals, we can anticipate a 
significant workload to generate. This work will be processed through 
the staff and laboratory already anticipated. Philosophically, it is 
the Region's policy to protect the waste water treatment plants 
through point source control at the industries. 

Waste Water Treatment Plant Discharges 

This is the area of large, capital intensive upgrades and expansions. 
In order to achieve no degradation of receiving water quality 
objections, an expansion to a waste water treatment plant 
automatically triggers mare stringent discharge criteria. 

In order to maximize the servicing ability for waste water treatment 
and not overstress the receiving watercourse, the Region and Ministry 
of the Environment have attempted to balance loading throughout the 
drainage basin. You will hear more of this in a paper this afternoon. 

I will illustrate what happens to project costs as these new 
objectives "click in". 

This project is the Cambridge (Gait) Waste Water Treatment Plant 
expansion/upgrade. I would like to demonstrate several aspects of the 
enhancement grant. The discharge criteria for the expanded project 
are for a maximum 30 day consecutive average flow rate of 56,800 m 3 
play. 



- 52 - 



These are: 


Suspended Solids 


15 mg/1 




Total Phosphorus 


0.6 mg/1 




NH3-N 


2 mg/1 




B.O.D.5 


15 mg/1 



Non-compliance levels were established as 
B.O.D. - 25 mg/1. Phosphorous 0.6 mg/1 
S.S. - 25 mg/1. Ammonia 3 mg/1 

It is also necessary in this facility to provide for no planned 
by-passes. These costs are based on estimates included in the "Draft" 
Pre-Design report. 

1. 33% subsidy on items that are required for purposes of 
plant upgrading to meet more stringent requirements 
of M.O.E., etc. 

- No "planned" bypasses 

- Reduced anmonia - nitrogen in effluent 

- No Increase in phosphorus discharge 



2. Items as per cost estimates in Pre-Design Report 

i) Raw Sewage Pump Station $1,280,000 - 

to meet "noplanned by-passes", capacity in excess 

of peak dry weather flow to meet no by-passing 

requirement i.e. 

PDWF $ 90,900 m3/day 

PWWF 171,100 m3/day 

Difference 80,200 n^/day 

80.200 x $1,280,000 $ 600,000 

171,100 



- 53 - 



ii) Aeration Tanks - $2,850,000 

Increase in capacity of expansion purposes 

56,800 - 38,600 - 18,200 m3/day 

Increase in capacity of nitrification 

purposes 

38,600 - 21,000 - 27,600 m3/day 

For nitrification purposes 

- 17,600 x 1,850,000 $1,400,000 

18,200 + 17,600 

iii) Blower Bldg/Return 

Sludge Pumping - $1,700,000 

Same % as aeration tanks $ 836,000 



iv) Final Clarifiers $1,590,000 
Surface area existing 1641m 3 
To increase capacity of expansion 
would require 56.000 - 38,650 

38,600 

- 51.8$ i.e. - 850 m2 

Actual increase - 1508 m 2 
Part for nitrification - 
1508-850 - 658 m2 
therefore costs for nitrification 

- 658 x $1,590,000 - $ 722,000 
1508 



- 54 - 



v) Effluent Filtration - $2,400,000 

the entire item is for purposes of 

increased restrictions on phosphorus 

discharges $2,400,000 



vi) Ultraviolet Reactors - $1,100,000 
38,600 x 100% is for 
56,800 
Improved effluent (68%) 

18,000 x 100% - 32% 

56,800 

is for expansion purposes 

therefore 68% x $1,100,000 is 

for Improved effluent and more 

restrictive handling/ feeding 

facilities $ 746,800 



vii) Electrical - $900,000 

This is difficult to apportion. 

Items which relate to more restrictive 

requirements include 

- standby power to eliminate by-passing 

- increased treatment particularly 
aeration to meet reduced anmonia - 
nitrogen requirements. 

- effluent filtration to meet 
reduced phosphorus concentrations 
on the plant effluent 



- 55 - 



It would seem that at least 50% of 

the costs relate to the increased 

treatment requirements $ 450,000 

vlii) Effluent Pumping Requirement - $250,000 
This entire item is for purposes of 
increased environmental proctectlon $ 250,000 

ix) Site Improvements - $500,000 
Very little of this item is for 
enhanced treatment but perimeter berms 
are for increased environmental 
protection $ 75,000 

x) Instrumentation & Control - $1,000,000 
This item is difficult to assess but we 
would suggest 1/3 of the requirements 
would relate to enhanced treatment 
facilities $ 330,000 

xi) Modifications to Digesters - $500,000 
This is an allowance suggested for 
possible repairs/modifications. 50% 
could be assessed as for upgrade 
modifications $ 250,000 

Sub-Total $8 , 061 , 000 

10% Estimating Cost 806,000 

TOTAL $8.867,000 

33% Grant would be $2,926,000 

if only 15% Grant 

would be $1,330,000 



- 56 - 



When the plant was re-rated to establish the capacity of the facility 
at the new discharge criteria the plant was found to have a hydraulic 
capacity of 4.62 MIGD. The Region feels the enhancement grant should 
be applied to the lost capacity already installed at the plant. 
Therefore, we are asking for a 33% enhancement grant on: 

12.5 - 4.62 x $21.2 million - $13.36 million 
12.5 

instead of $8.87 million. This amounts to an increased request of 
$1.48 million. 



- 57 - 



PANEL DISCUSSION 

The final session consisted of a lively panel discussion. 
Panel members included several of the presenters, with the 
addition of George Powell, of Gore & Storrie Limited, 
Werner Lewandowski, of the Ministry of the Environment, and 
Bruce Jank, of the Wastewater Technology Centre.